FEDERAL REAL 

PROPERTY

More Useful 

Information to 

Providers Could 

Improve the 

Homeless Assistance 

Program

Report to the Committee on Homeland 

Security and Governmental Affairs, 

U.S. Senate

September 2014

GAO-14-739

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-739, a report to the 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

September 2014

FEDERAL REAL PROPERTY

More Useful Information to Providers Could Improve 

the Homeless Assistance Program 

Why GAO Did This Study

Title V of the McKinney-Vento 

Homeless Assistance Act enacted in 

1987 created a program to assist the 

homeless, in part, by identifying 

unused federal real property and 

making it available to homeless 

assistance providers.

GAO was asked to review the 

implementation of Title V of the 

McKinney-Vento Homeless Assistance 

Act. This report examines: (1) the 

identification and transfer of federal 

real property to homeless assistance 

providers and (2) the benefits and 

challenges homeless assistance 

providers and national advocacy 

organizations reported in identifying, 

acquiring, and using federal real 

property, and the potential actions that 

could help to address these 

challenges. GAO obtained information 

and data from HUD and the 

Department of Health and Human 

Services (HHS) on the properties 

reported since the program’s inception 

and interviewed officials from GSA, 

HHS, and HUD. GAO also obtained 

views on the program from officials at 

(1) nine federal agencies, representing 

a range of size in their real property 

portfolios; (2) eleven homeless 

assistance providers (including eight 

that received property), representing a 

range of locations, size of property, 

and services provided; and (3) national 

homeless-advocacy organizations. 

What GAO Recommends

Congress should consider changing 

(1) the scope of properties to be 

reported to HUD with respect to the 

types of properties that may be less 

likely to be useful to assist the 

homeless and (2) the frequency of 

Federal Register reporting.

What GAO Found

Since inception in 1987, the nationwide Title V homeless-assistance program has 

transferred 122 properties from federal agencies to homeless assistance 

providers. Of these properties, 81 are currently being used to provide a range of 

homeless assistance services nationwide. Such services include transitional 

housing, referral services, and emergency shelter. However, few of the 

properties that the Department of Housing and Urban Development (HUD) has 

listed as suitable and available since the program’s inception received 

applications from homeless assistance providers. In most cases, the properties 

may not have actually been practical for homeless service providers to use. For 

example, in 2013 about 80 percent of these properties were for off-site use 

only—meaning that a provider would need to physically move the property in 

order to use it. HUD officials told us that they would prefer that agencies not be 

required to report certain types of properties at all, such as those for off-site use 

only. The current statutory requirement for agencies to report all properties that 

fall within four broad categories—excess, surplus, underutilized, and unutilized—

may not be effective for certain types of properties. Such exclusion could allow 

HUD officials to focus on the suitable and available properties that may be more 

likely to assist the homeless. 

Of the 11 homeless assistance providers we interviewed, the eight case study 

providers that acquired property cited benefits from the Title V homeless 

assistance program, such as expanding services and obtaining real property at 

no cost. These benefits notwithstanding, the providers identified challenges, such 

as identifying available properties. These findings are consistent with reports 

from national homeless advocacy organizations. HUD reports properties in the 

Federal Register multiple times a year as required. The United States 

Interagency Council on Homelessness (USICH), which plays a coordination role, 

provides a link on its website to the HUD reports. Nonetheless, according to 

national homeless advocates, many homeless assistance providers remain 

unaware of the availability of properties because the Federal Register is not userfriendly. Further, HUD lists many of the same properties more than once in the 

Federal Register, as required, even though they may not be useful to homeless 

assistance providers. In the past, some in Congress and the executive branch 

have raised issues about reporting requirements; the basic issue has been that 

some requirements result in reports that may be burdensome to produce, or not 

very useful. Modifying reporting requirements to reduce the frequency of 

reporting related to properties that are less likely to be useful to homeless 

providers could help, while also allowing HUD to continue to fulfill its 

responsibilities.

View GAO-14-739. For more information, 

contact David J.Wise at (202) 512-2834 or 

wised@gao.gov.
Page i GAO-14-739 Federal Real Property

Letter 1 

Background 4

122 Properties Transferred Have Provided a Range of Homeless 

Assistance Services, but Many Properties Reported and 

Deemed Suitable for Homeless Assistance May Not Be Useful 

for That Purpose 11

Homeless Assistance Providers Expanded Services, but Some 

Reported Encountering Challenges in Identifying, Applying for, 

and Using Real Property 24

Conclusion 33

Matter for Congressional Consideration 34

Recommendations for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I Scope and Methodology 39

Appendix II Sample Title V Checklist Submitted by Landholding Agencies to 

HUD 43

Appendix III List of Landholding Agencies HUD Canvasses for Title V 48

Appendix IV Services Provided at 81 Active Properties Transferred under Title V, 

by State 49

Appendix V Eight Homeless Assistance Case-Study Properties 57

Appendix VI Comments from the General Services Administration 65

Appendix VII Comments from the Department of Health and Human Services 67

Contents
Page ii GAO-14-739 Federal Real Property

Appendix VIII Comments from the U.S. Interagency Council on Homelessness 69

Appendix IX GAO Contact and Staff Acknowledgments 70

Tables

Table 1: Categories of Real Property That Landholding Agencies 

Must Report to the Department of Housing and Urban 

Development (HUD) 6

Table 2: Types of Homeless Assistance Services Offered at the 

81 Active Properties, as of March 31, 2014 14

Table 3: Examples of Suitable and Available Properties in 2013 

That May Not be Practical for Homeless Assistance Use 17

Table 4: Number of Properties HUD Reported Suitable and 

Available for “Off-site Use Only” 18

Table 5: Department of Housing and Urban Development’s (HUD) 

Federal Register Reporting Requirements 27

Table 6: Services Provided at 81 Active Properties Transferred 

under Title V, by State 49

Figures

Figure 1: The Title V Homeless Assistance Program Process 5

Figure 2: Geographic Distribution of 81 Currently Active Properties 

as of March 31, 2014 13

Figure 3: Estimated Number of Properties Potentially Available for 

Homeless Assistance Compared to the Total Number of 

Properties Transferred under the Title V Homeless 

Assistance Program, 1987–2014 15

Figure 4: Former Social Security Administration Building 57

Figure 5: Former Lowry Air Force Base Building 58

Figure 6: Former Homestead Air Force Base 59

Figure 7: Former U.S. Coast Guard Family-Housing Site 60

Figure 8: Former Social Security Administration Building 61

Figure 9: Former Sonstelie Hall Army Reserve Center 62

Figure 10: Former Naval Reserve Center 63

Figure 11: Former U.S. Coast Guard Housing 64
Page iii GAO-14-739 Federal Real Property

Abbreviations 

ARCH A Regional Coalition for Housing

BRAC Base Realignment and Closure Act 

DOD Department of Defense

DOE Department of Energy

DOI Department of the Interior

EPA Environmental Protection Agency

GSA General Services Administration 

HHS Department of Health and Human Services 

HUD Department of Housing and Urban Development 

LRA local redevelopment authority

OMB Office of Management and Budget

NLEC New Life Evangelistic Center 

OneCPD Community Planning and Development Web site

USICH U.S. Interagency Council on Homelessness 

VA Department of Veterans Affairs

VOALA Volunteers of America of Los Angeles

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Page 1 GAO-14-739 Federal Real Property

441 G St. N.W.

Washington, DC 20548

September 30, 2014

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

Estimates of the homeless population in the United States vary widely. 

According to the Department of Housing and Urban Development (HUD) 

610,042 people in the United States were homeless on a single night in 

January 2013, and more than a third of these people were living in

unsheltered locations, such as under bridges, in cars, or in abandoned 

buildings.1 According to the National Law Center on Homelessness and 

Poverty, the numbers of Americans experiencing homelessness is 

estimated between 1.5 million to 3.5 million in a given year.2 At the same 

time, we have previously reported that federal agencies continue to hold 

thousands of unneeded and underutilized properties that annually cost 

the government over a billion dollars to operate.3 As a result of this and 

other long-standing problems, we have designated federal real property 

as a high-risk area.4

 

1 U.S. Department of Housing and Urban Development, The 2013 Annual Homeless 

Assessment Report (AHAR) to Congress, (Washington, D.C.: 2013). Of the 610,042, 

394,698 people were homeless in sheltered locations and 215,344 were living in 

unsheltered locations.

Title V of the McKinney-Vento Homeless Assistance 

Act (the Act), as amended, created a program to assist the homeless, in 

part, by using public resources and programs—including unused federal 

2 National Law Center on Homelessness and Poverty. This Land Is Your Land: How 

Surplus Federal Property Can Prevent and End Homelessness (Washington, D.C.: 

October 2013).

3 GAO, Federal Real Property: The Government Faces Challenges to Disposing of 

Unneeded Buildings. GAO-11-370T (Washington, D.C.: Feb. 10, 2011).

4 GAO, High Risk Series: An Update. GAO-13-283 (Washington, D.C.: February 2013).
 

Page 2 GAO-14-739 Federal Real Property

real property—in a more coordinated manner to meet the needs of 

homeless Americans.5

In general, Title V of the Act requires federal landholding agencies to 

identify and make available for homeless assistance real property under 

their control that they are not fully utilizing or no longer need before 

properties are disposed through other means. If a property is published 

by HUD as suitable and available, eligible applicants, such as homeless 

assistance providers and local governments, may apply to obtain the real 

property at no cost for the provision of a broad range of services for the

homeless, including shelter, job training, and storage.

However, implementing the Title V homeless assistance program 

requirements has presented challenges. Our prior work has found that 

legal and budgetary challenges continue to hamper agencies’ disposal 

efforts. Since much of the unneeded federal real property may have no 

remaining useful life, may require extensive environmental remediation, 

may be located within secure compounds, or require off-site removal, it, 

for example, may not be useful to assist the homeless.6

1. The identification and transfer of federal real properties for homeless 

assistance under the Title V homeless assistance program.

You asked us to 

determine how this program is performing both in terms of government 

operations and for homeless assistance providers. This report addresses 

two objectives:

2. The benefits and challenges homeless assistance providers and 

national advocacy organizations reported in identifying, acquiring, and 

using federal real property, and potential actions that could help 

address these challenges.

To determine what is known about the identification and transfer of 

federal real properties for homeless assistance under Title V, we 

reviewed the requirements of Title V of the Act as they apply to the 

 

5 Pub. L. No. 100-77, 101 Stat. 482 (1987). The Stewart B. McKinney Homeless 

Assistance Act, enacted in 1987, was renamed the McKinney-Vento Homeless Assistance 

Act in October 2000 by Pub. L. No. 106-400, 114 Stat. 1675 (2000). For the purposes of 

this report, we will refer to this program as the Title V homeless assistance program.

6 GAO, Federal Real Property: Progress Made Toward Addressing Problems, but 

Underlying Obstacles Continue to Hamper Reform, GAO-07-349 (Washington, D.C.: Apr. 

13, 2007).
 

Page 3 GAO-14-739 Federal Real Property

General Services Administration (GSA), the Department of Health and 

Human Services (HHS), HUD, and the U.S. Interagency Council on 

Homelessness (USICH). We obtained estimates from HUD of the number 

of underutilized, unutilized, excess, and surplus properties reported by 

landholding agencies and the number that HUD determined to be suitable 

and published as available for homeless use since the program’s 

inception in 1987 through March 31, 2014—the date of the most recently 

available information. To assess the reliability of these estimates, we 

interviewed officials from HUD about how the estimates were derived and 

determined that the information provided by the agency provides a 

reasonable basis, with caveats, for reporting the number of properties that 

have been screened and found suitable and available. In addition, to 

determine the types of properties reported, we analyzed HUD’s annual 

reports of suitable/available and suitable/unavailable properties for years 

2008 through 2013. This time frame was selected to include the 5 years 

prior to this audit. When HUD’s annual report for 2013 became available, 

we added it to the analysis to include the most recent information. From 

HHS, we also obtained documents and data on the number of notices of 

interest and applications it received for properties made available for 

homeless assistance from the program’s inception in 1987 through March 

31, 2014. To assess the reliability of these data, we interviewed officials 

from HHS about how the data are collected and maintained, and the 

importance to the agency of ensuring the completeness of this data, and 

we determined that the data were sufficiently reliable for the purposes of 

our report. To understand how federal landholding agencies identify and 

report real property to HUD pursuant to the Act’s requirements, we 

selected nine landholding agencies to include a range of size among real 

property portfolios of land and buildings, including GSA, HHS, the three 

Department of Defense service branches––the U.S. Army, U.S. Air Force, 

and U.S. Navy––the Department of Energy (DOE), the Department of the 

Interior (DOI) and the Department of Veterans Affairs (VA),

7 and the

Environmental Protection Agency (EPA).8

 

7 After preliminary audit work, we did not continue our work at VA because we learned 

that very little of VA’s property becomes available for Title V purposes.

We interviewed agency officials 

from GSA, HHS, HUD, and USICH to understand how they process 

properties reported under Title V homeless assistance program 

8 Altogether, GSA, HHS, and the other seven landholding agencies we reviewed account

for almost 90 percent of real property held by the federal government in 2012. According 

to HUD officials, HUD is not a landholding agency.
 

Page 4 GAO-14-739 Federal Real Property

requirements. We also interviewed agency officials from the nine 

landholding agencies to obtain their views on how they meet the Act’s 

requirements and their impact on each agency’s disposal process. To 

determine the benefits and challenges that homeless assistance 

providers and national advocacy organizations report in identifying, 

acquiring, and using federal real property and potential actions that could 

help address those challenges, we selected eight homeless assistance 

organizations that acquired federal real property under the program 

based on criteria such as the size of the real property acquired under the 

program, the services provided, geographic distribution, range of 

experiences, and suggestions from agencies and homeless advocacy 

organizations. We interviewed representatives from each of the selected 

organizations, reviewed documentation, and conducted site visits to two 

properties transferred under the Title V homeless assistance program. 

We also convened a virtual discussion panel comprised of 

representatives from three homeless assistance organizations whose 

applications for federal real property were not approved and interviewed 

representatives from two national homelessness-advocacy organizations 

(see app. 1 for more information on our scope and methodology).9 We 

conducted this performance audit from September 2013 to September 

2014 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

The McKinney-Vento Homeless Assistance Act created over a dozen 

programs intended to comprehensively address the needs of homeless 

Americans. Among these, the Title V homeless assistance program 

requires federal landholding agencies to make available real property that 

they identify as excess, surplus, unutilized, or underutilized for possible 

use to assist the homeless. Title V of the Act designated GSA, HHS, and 

HUD to administer the program. In addition, Title II of the Act created 

what is now known as USICH, an independent establishment within the 

Executive Branch whose mission is to coordinate the federal response to 

 

9 The national advocacy organizations were the National Coalition for the Homeless and 

the National Law Center on Homelessness and Poverty.

Background
 

Page 5 GAO-14-739 Federal Real Property

homelessness. The mission of USICH is to create a national partnership 

to act as a coordinating body between the federal government and the 

private sector to end homelessness nationally. Title V specifies a number 

of steps that federal landholding agencies, the three federal agency 

administrators of the program, and USICH must take to make federal real 

property—including land and buildings, or both—available for homeless 

assistance. Figure 1 summarizes key steps in the process and the time 

frames required to perform those steps.

Figure 1: The Title V Homeless Assistance Program Process

a Some agencies (e.g. DOI and the U.S. Navy) submit Title V checklists on an ongoing basis during 

the interim between the quarterly canvasses.

b HHS has a maximum of 25 days from the date a completed application is received to evaluate the 

application.

c HHS has a process by which the approved program of use may be changed as needed.
 

Page 6 GAO-14-739 Federal Real Property

HUD canvass: HUD surveys the landholding agencies that must identify 

and report to HUD on a quarterly basis real property that is excess, 

surplus, underutilized, or unutilized (see table 1).10

Table 1: Categories of Real Property That Landholding Agencies Must Report to the Department of Housing and Urban 

Development (HUD)

Property category Description Where defined

Excess property Property that an agency has determined is not required to 

meet the agency’s needs or responsibilities. 

42 U.S.C. § 11411(i)(2) which incorporates by 

reference 40 U.S.C. § 102(3). 

Surplus property An excess property that GSA has determined is not 

required to meet the needs or responsibilities of all federal 

agencies.

42 U.S.C. § 11411(i)(2) which incorporates by 

reference 40 U.S.C. § 102(10).

Underutilized property Property used only irregularly, intermittently, or partially for 

current agency mission needs.

Implementing regulations promulgated by HUD, 

GSA, and HHS (24 C.F.R. § 581.1; 45 C.F.R. § 

12a.1; 41 C.F.R. § 102-75.1160). 

Unutilized property Property not occupied for current program purposes. Implementing regulations promulgated by HUD, 

GSA, and HHS (24 C.F.R. § 581.1; 45 C.F.R. § 

12a.1; 41 C.F.R. § 102-75.1160). 

Source: GAO analysis. | GAO-14-739

Once landholding agencies (currently 25 in total) receive HUD’s quarterly 

canvassing letter, they have 25 days to respond. To collect such 

information, HUD asks landholding agencies to complete a “Title V 

checklist” for each of the excess, surplus, underutilized, or unutilized 

properties that they have identified and are required to report.11

Suitability determination: HUD assigns each reported real property a 

unique identification number and enters the checklist information into an 

electronic database. Based on the checklist, HUD must determine the 

suitability of each real property for homeless assistance. According to

implementing regulations, all real property––land, buildings, or both––are 

The 

checklist is a HUD document that requires the landholding agency to 

provide a variety of summary information about the real property, 

including its utilization status, accessibility (e.g., in a remote location or 

behind a secure perimeter), environmental condition, agency contacts, 

and other information (see app. II for an example of this checklist).

 

10 A “landholding agency” is a federal department or agency with the statutory authority to 

control real property. 42 U.S.C. § 11411(i)(3).

11 See app. III for a list of the 25 landholding agencies HUD currently canvasses.
 

Page 7 GAO-14-739 Federal Real Property

suitable unless a property’s characteristics include one or more of the 

following conditions:

• national security concerns, meaning a property is located in an area 

where the general public is denied access in the interest of national 

security;

• flammable or explosive materials within 2000 feet of the property;

• located in an airport runway clear zone or military airfield clear zone;

• located in a floodway;

• documented deficiencies, meaning a property with a documented and 

extensive condition(s) that represents a clear threat to personal 

physical safety, including structural damage or certain types of 

environmental contamination; or

• inaccessible, meaning a property is not accessible by road.12

After HUD makes a suitability determination, it is to provide this 

information to the reporting landholding agencies for review, as well as for 

the Federal Register listing that briefly describes the property’s condition 

and status (e.g., underutilized, unutilized, excess, or surplus).13

HUD also communicates with GSA, the federal government’s realproperty disposal agent, to identify excess real properties that landholding 

agencies have reported to GSA for disposal. If, however, a landholding 

agency reports real property to GSA that has not been submitted to HUD 

for a Title V suitability determination, GSA is required to create a Title V 

checklist and forward it to HUD.

Landholding agencies then have 45 days to make any edits, as noted in 

figure 1, such as changes in the property’s status. In addition, landholding 

agencies must transmit to HUD a statement of the availability of real 

property, declaring for example that a property is available for homeless 

assistance or explaining why a property cannot be made available for 

homeless assistance, such as in the case of a further compelling federal 

need for the property.

14

Publication of properties and holding period: Title V requires HUD to 

publish in the Federal Register all properties it reviewed. HUD’s Federal 

 

12 24 C.F.R. § 581.6 (a); 41 C.F.R. § 102-75.1185(a); 45 C.F.R. § 12a.6(a).

13 42 U.S.C § 11411(b), (c). 

14 24 C.F.R. § 581.5(c); 41 C.F.R. § 102-75.1180(c); 45 C.F.R. § 12a.5(c). 
 

Page 8 GAO-14-739 Federal Real Property

Register listings typically classify these properties as: 1) suitable and 

available for homeless assistance; 2) suitable but unavailable for 

homeless assistance; or 3) unsuitable for homeless assistance. Once 

published, homeless assistance providers––including state and local 

governments or eligible private non-profit organizations15––have 60 days 

to submit a “notice of interest” for suitable and available properties, and 

then 90 days from the date of the “notice of interest,” to submit an 

application to HHS.16

In addition to publication in the Federal Register, the requirements of Title 

V require GSA, HHS, and HUD to make such efforts as are necessary to 

ensure the widest possible dissemination of the listing information of 

available properties. For example, HUD is required to forward lists of all 

real property published in the Federal Register to USICH, which then 

must distribute relevant portions of the list to state and regional homeless 

coordinators. Also, when HUD determines an excess real property is 

suitable and publishes it in the Federal Register as available, the 

implementing regulations require GSA to concurrently notify HHS, HUD, 

and state and local governments, in addition to homeless assistance

providers that have expressed interest in the particular real property, and 

other organizations, as appropriate, concerning suitable properties.

The real property is not available for any other 

purpose during the 60-day or 90-day period or during the period in which 

HHS reviews the application. Interested parties also have 20 days to 

challenge the suitability determination of real property HUD found 

unsuitable for homeless assistance. If a notice of interest is not filed for a 

suitable and available real property within 60 days of its listing in the 

Federal Register, the disposal agency may then proceed with its routine 

disposal process, in accordance with applicable law.

17

Notices of interest and application: HHS is to evaluate applications of 

homeless assistance providers on a first-come, first-serve basis using five 

 

15 If the application is for a deed conveyance of the property (meaning that the title of the 

property passes from the government to the grantee) as opposed to a lease, the private 

sector organizations must be incorporated under section 501(c)(3) as tax-exempt 

organizations.

16 Written notice of intent to apply for a property may also be filed after the 60-day holding 

period. Such applications may be approved if the property remains available for homeless 

assistance use. 

17 42 C.F.R. § 581.5(f); 41 C.F.R. § 102-75.1180(f); 45 C.F.R. § 12a.5(f).
 

Page 9 GAO-14-739 Federal Real Property

criteria defined in HHS implementing regulations.18

• Proposed service offering: the extent and range of proposed services, 

such as meal, shelter, job training, and counseling. 

HHS may specify 

additional criteria for the application package for a given real property if it 

deems it necessary. The criteria are as follows:

• Need: the demand for the program and the degree to which the 

available real property will be fully utilized. 

• Implementation time: the amount of time necessary for the proposed 

program to become operational.

• Experience: demonstrated prior success in operating similar programs 

and attestations by federal, state and local authorities. 

• Financial ability: the adequacy of funding that will likely be available to 

fully run the proposed program and operate the facility. 

HHS review of application, application approval, and transfer of 

property: HHS is to review applications for completeness and, in some 

cases, may request additional information from the applicant, as

necessary. Evaluations must be completed in 25 days from the receipt of 

the completed application.

If HHS approves an application for underutilized or unutilized real 

property, the landholding agency can execute a lease of the property to 

the applicant. In the case of surplus real property, the disposal agency 

“assigns” the property to HHS, which then becomes the sponsoring 

agency and transfers the deed to the applicant. Grantees of federal 

properties under the Title V homeless assistance program must utilize the 

property in accordance with the approved application for the length of the 

lease or, in the case of deed conveyances, for 30 years.

Pursuant to HHS policies and procedures, HHS is to perform compliance 

oversight and ensure that the grantee uses the real property according to 

the terms in the approved application. To accomplish this, grantees are 

required to submit annual utilization reports to HHS, and HHS is to 

conduct site visits of the properties at least once every 5 years. In the 

event that a grantee is not implementing or is unable to implement the 

 

18 45 C.F.R § 12a.9(e)(2).
 

Page 10 GAO-14-739 Federal Real Property

program consistent with the approved application, the property title may 

revert back to the federal government.19

Title V of the Act has been amended several times, including by the Base 

Closure Community Redevelopment and Homeless Assistance Act of 

199420 (the Redevelopment Act or Act). According to HUD, this Act aimed 

to improve the process for disposing buildings and property at military 

installations under the existing base closure laws. Under the Act, which 

became effective shortly after the beginning of fiscal year 1995, 

Department of Defense (DOD) properties disposed under the Defense 

Base Closure and Realignment Act of 199021 were no longer subject to 

the Title V homeless assistance program requirements. According to 

HUD, many individuals involved in military base reuse concluded that 

Title V did not adequately address the multiple interests related to large 

parcels of surplus federal properties such as military bases. In general, 

with respect to the disposal of buildings and property located at 

installations approved for closure or realignment, the Redevelopment Act 

substituted a community-based process for the Title V homeless 

assistance program, in which the local redevelopment authority prepares 

a reuse plan after consulting with representatives of the homeless and

other community groups affected by the base closure, and HUD ensures 

that the plan appropriately balances the needs of the community for 

economic and other development with the needs of the homeless.22

 

19 According to HHS, reversion for reasons of noncompliance is typically a measure of last 

resort and undertaken only when other attempts at bringing the grantee into compliance or 

a retransfer to another provider have failed.

We 

excluded from this report facilities on military bases closed after 1994 and 

subject to the provisions of the Redevelopment Act, as we are reviewing 

implementations of the Act’s provisions separately and plan to report on 

the results in 2015.

20 Pub. L. No. 103-421, 108 Stat. 4346.

21 Pub. L. No. 101-510, 104 Stat. 1485,1808.

22 Such properties are subject to a process that involves Local Redevelopment 

Authorities’ (LRA) consultation with representatives of the homeless in the communities in 

the vicinity of the installation concerned to determine the need for homeless assistance 

and how portions of the former military installations might be used to meet it. LRA 

redevelopment plans are reviewed by HUD. Homeless assistance providers apply to the 

LRA for property on such installations that might be used to assist the homeless.
 

Page 11 GAO-14-739 Federal Real Property

Several court orders resulting from a 1988 lawsuit filed by the National 

Law Center on Homelessness and Poverty (National Law Center) and 

other advocates for the homeless have also shaped the implementation 

requirements of the Title V homeless assistance program. The 1988 

lawsuit alleged, and the court found, that the federal government was not 

fully complying with some Title V requirements. The court issued an order 

in 1993 imposing requirements beyond those mandated by the statute 

and implementing regulations, such as more comprehensive reporting 

requirements and expanded outreach. Unlike the 1993 District Court 

order, a more recent 2013 order does not require widespread changes to 

operational administration of the Title V homeless assistance program but 

rather seeks to better educate the landholding agencies about canvassing 

their real property and improving the quality of data reported by these 

agencies for Title V requirements and the Federal Real Property Profile.23

Under the Title V homeless assistance program, providers have used 

over 100 transferred properties since program inception through March 

31, 2014, to deliver a range of services across the country. However, few 

of the properties that HUD has determined to be suitable and were

available for homeless assistance since the program’s inception received 

applications from homeless assistance service providers. In most cases, 

properties screened and determined as suitable and available may not 

have actually been practical for homeless service providers to use. For 

example, our analysis of HUD’s annual reports from 2008 through 2013 

found most of the properties published as suitable and available were for 

off-site use only—meaning that a provider would need to physically move 

the property in order to use it.

 

23 The Federal Real Property Profile, created pursuant to Executive Order 13327, is the 

federal government’s inventory system that is to contain data on all real property assets 

within and outside the United States, including improvements on federal land. Executive 

Order No. 13327, Federal Real Property Asset Management, 69 Fed. Reg. 5897 (Feb. 6, 

2004). 

122 Properties 

Transferred Have 

Provided a Range of 

Homeless Assistance 

Services, but Many 

Properties Reported 

and Deemed Suitable 

for Homeless 

Assistance May Not 

Be Useful for That 

Purpose
 

Page 12 GAO-14-739 Federal Real Property

The Title V homeless assistance program has provided properties with 

useful facilities. As of March 2014, of the 122 properties transferred since 

the program’s inception in 1987, 81 properties are currently in use by 

providers. For the other 41 properties, there are several explanations as 

to why they are no longer in use for homeless assistance. For example, 

leases for 9 properties were rescinded for failure to use the properties for 

the agreed upon purposes, and deeds for 8 properties reverted to the 

government for reasons such as non-compliance or by request of the 

grantee. Across the country homeless assistance providers use the 81 

properties to provide a range of homeless assistance services, such as 

supportive services, referral services, various forms of temporary or more 

permanent housing, administrative offices, and clothing or food 

distribution. The 81 active properties include approximately 470 buildings 

of about 1.5-million square feet and over 500 acres of land. The 

properties include a variety of facilities ranging in size from 1900 square 

feet to 512,000 square feet and vacant land ranging from almost two 

tenths of an acre to over 96 acres. Of the 81 currently active properties, 

not-for-profit organizations––such as the Salvation Army, Samaritan 

House, and Volunteers of America––acquired 69, and local governments 

acquired 12. A few local governments formed public/not-for-profit 

collaborations to develop the properties. Figure 2 shows the geographic 

distribution of the properties.

Homeless Assistance 

Providers Currently Use 

81 Title V Properties for a 

Range of Services across 

the Country
 

Page 13 GAO-14-739 Federal Real Property

Figure 2: Geographic Distribution of 81 Currently Active Properties as of March 31, 2014

Note: Red “bulls-eyes” represent the geographical location of Title V homeless assistance program 

properties. There may be more than one Title V homeless assistance program real property at a 

given location. For example, seven Title V homeless-assistance program properties are located at 

Fort Ord in Monterey, California.
 

Page 14 GAO-14-739 Federal Real Property

Providers at 60 of the 81 currently active properties offer multiple services 

to homeless individuals. For example, one provider said it offers support 

services such as substance abuse counseling, mental health services, 

case management, job training and placement. Another provides 

emergency, transitional, and permanent supportive housing; a health 

clinic; and daycare services. A third uses a former army depot to 

distribute goods and clothing (see table 2 for more information on the 

types of services provided and app. IV for more information on the 

services provided at each of the 81 locations). According to the National 

Law Center’s 2011 estimate,24

Table 2: Types of Homeless Assistance Services Offered at the 81 Active 

Properties, as of March 31, 2014

more than 2.4 million homeless Americans 

each year have received assistance through the Title V homeless 

assistance program since its inception.

Services offereda Number of providers offering services

Supportive servicesb 43

Transitional housingc 42

Referral services 37

Emergency shelterd 19

Permanent supportive housinge 12

Administrative offices 11

Goods/clothing distribution 8 

Education/job training 6 

Daycare/day center 5 

Food distribution 2 

Mental Health 2 

Warehouse and storage 2 

Case management 1 

Source: GAO analysis of HHS information. | GAO-14-739

a Many service providers offer multiple services at the same location based on HHS data. For 

example, 26 of the 81 service providers offer three different types of services.

b Supportive services is a broad category that may include services such as child care; employment 

assistance; employment counseling; outreach, advocacy, life skills training, and housing search, and 

counseling services; outpatient health services; trauma counseling and victim services.

 

24 Federal Property Disposal: Hearing before the House Committee on Oversight and 

Government Reform, 112th Cong. (2011) (statement of Ms. Maria Foscarinis, Executive 

Director, National Law Center on Homelessness & Poverty). 
 

Page 15 GAO-14-739 Federal Real Property

c Transitional housing is designed to provide housing and appropriate supportive services to 

homeless persons to facilitate movement to independent living within 24 months, or a longer period 

as approved by HUD.

d Emergency shelter is any facility with overnight sleeping accommodations, to provide temporary 

shelter for the homeless.

e Permanent supportive housing is long-term, affordable, community-based housing that is linked to 

appropriate supportive health and social services (e.g., substance abuse, mental health, case 

management, medical care services, and services for the disabled and frail elderly) that enable 

homeless individuals and homeless families with disabilities to maintain housing. There is no time 

limit to residency, provided a tenant meets the conditions of occupancy as established by the 

program.

Of the at least 10,000 properties determined to be suitable and available, 

approximately 1,200 properties received notices of interest, and we 

estimate that fewer than 400 properties received applications from 

homeless assistance providers, resulting in the transfer of 122 properties 

to assist the homeless in the 26 years since Title V’s inception through 

March 2014 (see fig. 3).

Figure 3: Estimated Number of Properties Potentially Available for Homeless 

Assistance Compared to the Total Number of Properties Transferred under the Title 

V Homeless Assistance Program, 1987–2014

According to HHS data, since the inception of the program in 1987, most 

properties deemed by HUD to be suitable and which are available for 

homeless assistance have not received notices of interest or applications 

Few Properties Deemed 

Suitable and Available for 

Homeless Assistance 

Were of Interest or 

Received Applications 

from Service Providers
 

Page 16 GAO-14-739 Federal Real Property

from homeless service providers. In addition, we found that in many 

cases, suitable and available properties may not have been practical for 

homeless service providers to use. Our analysis of HUD’s 2013 annual 

report published in the Federal Register found 630 properties published 

as suitable and available including buildings ranging from a 12 square 

foot storage shed to a 75,720 square foot building in a restricted area, 

and vacant land ranging from about one hundredth of an acre to over 15 

acres. These properties may be inconveniently located at a distance from 

existing communities or public transportation, within a military installation, 

or in poor condition––conditions consistent with what we found in our 

prior work (see table 3).25

 

25 GAO, Federal Real Property: Most Public Benefit Conveyances Used as Intended, but 

Opportunities Exist to Enhance Federal Oversight. GAO-06-511 (Washington, D.C.: June 

21, 2006).
 

Page 17 GAO-14-739 Federal Real Property

Table 3: Examples of Suitable and Available Properties in 2013 That May Not be Practical for Homeless Assistance Use 

Location HUD description of property

Dublin, CA Building, off-site use only: 30 square feet; control tower; poor conditions; restricted area; transferee 

must obtain real estate doc. to access/remove; contact Army for more information

West Sacramento, CA Building: 3,840 square feet; 9 months vacant; poor conditions; restricted area; transferee will need an 

escort to access property

St. George Island, FL Land: 0.34 acres; tower & fence needs to be removed; remote access; contact Air Force for more 

information

Ft. Benning, GA Building, off-site removal only; 192 square feet; Sep Toil/Shower; poor conditions; secured area; 

contact Army for info. on accessibility/removal

Hawaii National Park, HI Building, off-site removal only; 100 square feet; pollutant catch basin; poor conditions

Wahiawa, HI Building, off-site use only: 512 square feet; storage; 46 yrs.-old; poor conditions

Johnston, IA Building, remote/secured area: 3,076 square feet; family housing; 816+months vacant; deteriorated; 

escort required; contact Army for accessibility requirements

Mystic, IA Building, off-site removal only; 80 square foot storage shed; one plus months vacant; deteriorated

Ft. Riley, KS Building, off-site removal only; 128 square feet; latrine; deteriorating conditions; located on controlled 

area; contact Army for more information

Indian Head, MD Building, off-site use only: 480 square feet; chemical plant 20+yrs. vacant; contaminated; major 

renovations required for other use

Smithville, MO Building, off-site use only: 100 square feet; toilet needs extensive repairs

Lawton, OK Building, off-site use only: 24,072 square feet concrete block/w brick

Stigler, OK Building, off-site removal only; 24 square feet water well; poor conditions

Valliant, OK Building, off-site removal only; 12 square feet; storage; flammable materials; poor conditions

Charleston, SC Land: 5.59 acres; contamination; contact Navy for more information

Purdon, TX Building, off-site use only: 624 square feet; 30+ years; restroom

Source: GAO analysis of HUD’s 2013 Title V Annual Report. | GAO-14-739

As noted above, HUD is required to evaluate the properties and applies

criteria that are defined in implementing regulations. A landholding 

agency may indicate on the Title V checklist, for example, that a property 

has extensive deterioration, but according to HUD officials, if the 

landholding agency does not provide supporting documentation, HUD 

may deem the property suitable for homeless assistance. As a result, 

HUD designates many properties as suitable with deficiencies that may 

therefore make them less desirable to homeless assistance providers. 

The suitability criteria in HUD’s regulation for implementing the Title V 

homeless assistance program include provisions for excluding properties 

with deficiencies such as contamination, structural damage or extensive 

deterioration that are documented, extensive, and considered by HUD as 

representing a clear threat to personal safety. For example, while HUD 

did not determine conditions to rise to the level of a “documented 

deficiency,” our analysis of the 630 suitable and available properties 
 

Page 18 GAO-14-739 Federal Real Property

reported in the HUD’s 2013 annual report found properties with conditions 

described as “deteriorated” (35 properties) and in “very poor condition” 

(18 properties).

Moreover, almost 80 percent of the properties published as suitable and 

available in 2013 were for “off-site use only.” These properties refer to 

buildings and other removable structures that are located on land that is 

not surplus and, therefore, must be removed and relocated. According to 

officials from the National Law Center, the costs of moving the building, 

preparing the land on which to relocate the building, and making 

improvements needed to convert the building to provide services are 

often beyond the budget of the homeless-assistance service providers.

Officials from four of our nine selected landholding agencies told us they 

believe that properties for off-site use only are not practical for homeless 

assistance services. In addition, although an HHS official with 

responsibility for the Title V program told us that four of the 122 properties 

transferred under the Title V homeless assistance program were made 

available for off-site use only, these properties were trailers, which are 

designed to be easily moved, as opposed to other types of off-site 

properties described below, which may not be easy to move. For 2013, 

the most recent year reported, of the 630 properties HUD listed as 

suitable and available in the annual report, 78 percent were for “off-site 

use only” (see table 4).

Table 4: Number of Properties HUD Reported Suitable and Available for “Off-site Use Only” 

Year of 

reporting

Total number of 

properties 

reported to HUD

Number of properties 

that were 

“Suitable/Available” 

Percentage of total 

that were 

“Suitable/Available” 

 “Suitable/Available” 

properties that were 

for “off-site use only” 

Percentage of 

“Suitable/Available” 

properties that were 

for “off-site use only” 

2013 only 766 630 82% 489 78%

2008 – 

2013a 1,677 1,102 66% 859 78%

Source: GAO Analysis of HUD 2008-2013 Annual Reports published in the Federal Register. | GAO-14-739

a Our analysis of HUD’s annual reports published in the Federal Register for calendar years 2008 

through 2013 identified 1,677 properties reported over the 6 years, of which 982 (59 percent) 

appeared in more than one annual report and 288 (17 percent) appeared in each of the six annual 

reports.

Since the majority of properties reported as suitable and available in 2013 

were for off-site use only, as a result, they may be impractical for 

homeless assistance. For example, according to U.S. Army officials, 

since most of the Army’s properties reported under Title V are located on 

secured installations and do not involve the transfer of land, these 
 

Page 19 GAO-14-739 Federal Real Property

properties are often made available to homeless assistance providers for 

“off-site use only.” In addition, because most buildings in the Army’s 

inventory consist of masonry and steel, the removal of these properties is 

costly. As a result, U.S. Army officials said that very few homeless 

assistance providers have expressed interest in Army properties 

designated for “off-site use” since the program’s inception.26

USICH’s 2011 agency annual report stated that, because of the wide 

latitude in the suitability standard, a clear majority of the properties HUD 

finds “suitable” are not actually practical for homeless assistance.

Similarly, 

DOI officials told us that because the agency does not relinquish federal 

park lands, the buildings published as suitable and available located 

within federal parks are also designated for “off-site use only.” Many 

federal park lands are in remote areas, and moving a building from those 

locations can be costly.

27

An additional concern with HUD’s Title V data lies in the limitations of its 

Title V database that HUD uses to store information on properties 

reported by landholding agencies and report them to the public.

According to HUD officials, the agency has screened at least 40,000 

properties since the early 1990s, of which at least 10,000 (at least 24 

percent) were determined to be suitable and were available for homeless 

use (see fig. 3). These estimates are based on HUD’s Title V database, 

which was developed in the early 1990s, and maintains data on the 

properties reported to HUD by landholding agencies and HUD’s suitability 

As 

noted above, HUD considers all property suitable for homeless 

assistance unless a property’s characteristics meet one or more of six 

conditions, such as national security concerns or location in a floodway. 

The relatively large numbers of properties deemed by HUD to be suitable 

and that were available may give homeless assistance providers, the 

public, and other stakeholders a false impression as to what properties 

are of practical use for homeless assistance because they included a 

large proportion of properties that have substantial deficiencies. In turn, 

this may mislead stakeholders about the extent to which the federal 

government is providing federal real property for homeless assistance.

 

26 According to our analysis of HHS data, properties made available for “off-site use only” 

received fewer than 30 notices of interest from 1988 through March 31, 2014.

27 United States Interagency Council on Homelessness. Opening Doors: Appendix: 

Programs for People Experiencing Homelessness 2011 (Washington, D.C.: 2011).
 

Page 20 GAO-14-739 Federal Real Property

determinations.28 However, HUD’s database does not have the capability 

to generate reports on properties or data for the purpose of analyzing the 

properties reported for the Title V homeless assistance program. For 

example, when we asked HUD for reports from the database in order to 

perform our own analysis, such as the total number of properties 

reviewed for suitability and the total number published as suitable and 

available since program inception, the agency was unable to provide 

these data to us. The database was designed, and is primarily used, to 

generate listings of properties for publication in the Federal Register. The 

PDF format of the Federal Register reports poses challenges for 

automated analysis, and as a result, we had to manually count numbers 

of properties in specific categories to ensure the validity of our analysis, 

such as those for off-site use only reported in table 4. Standards for 

Internal Control in the Federal Government states that managers are 

responsible for providing reliable, useful, and timely information for 

transparency and accountability of programs and their operations.29

Reliability also means that for any computer processing of the data 

elements used, the results are reasonable, complete, and accurate. In 

addition, federal information technology guidance for publicly available 

data states that accessible data should be made available in convenient, 

modifiable formats that can be retrieved, downloaded, indexed, and 

searched.30 As the database cannot produce reports on the properties, 

HUD relies on hard-copy record keeping, which limits HUD’s ability to 

make information on properties readily available, requiring labor intensive 

use of resources to find needed data. This capability is important because 

Title V requires HUD to make available to the public upon request all 

information in its possession about all properties reviewed and not 

identified as suitable for the homeless—about 30,000 properties 

according to HUD’s estimate—including the reasons such properties were 

not so identified.31

 

28 HUD officials were uncertain when in the early 1990s the database was created and 

about the number of properties that were added to the database screened prior to its 

creation.

Moreover, HUD officials told us that during the recent 

litigation, the plaintiffs hired a contractor to make copies of the requested 

29 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington D.C.: November 1999). 

30 Executive Order No. 13642, Making Open and Machine Readable the New Default for 

Government Information, 78 Fed. Reg. 28111 (May 14, 2013).

31 42 U.S.C. §11411(c)(1)(C). 
 

Page 21 GAO-14-739 Federal Real Property

data from HUD’s hard copy files, and it took three individuals several 

weeks to complete the task. Without a comprehensive database that 

maintains this information, HUD would need to respond to such a request 

on up to 30,000 properties by manually looking through files, which would 

not be an efficient use of resources. Because HUD uses the database 

primarily for generating listings, it has not assessed the extent to which 

the benefits of modifying the database to generate electronic reports for 

the purposes of responding to information requests or performing 

analysis, or if developing a new database to do so would outweigh the 

costs. Modifying its database, or developing a new one that is 

electronically searchable, would better position HUD to respond to 

information requests.

While it is HUD’s role to assess the suitability of properties for use to 

assist the homeless, some federal landholding agencies report many 

properties to HUD that may not, in the landholding agencies’ estimation, 

be useful to assist the homeless. However, a few landholding agencies’ 

officials told us that they do not report such properties or other surplus, 

underutilized, and unutilized properties because the reporting 

requirements are labor intensive or the properties may not be useful to 

the homeless. As noted above, the Title V homeless assistance program 

requires quarterly reporting and completion of a checklist for each 

property. The following examples illustrate the variety of Title V reporting 

practices among the agencies we reviewed.

• U.S. Navy officials told us that they report only excess properties to 

HUD because of the size of their real property portfolio—

approximately 85 installations, and over 65,000 buildings and 

structures. According to these officials, the Navy does not have the 

resources to report on underutilized and unutilized property, which 

they said would require constant monitoring. Furthermore, the Navy

also does not report some properties within Navy installations that do 

not allow public access within certain areas.

• US Army officials said that they report eligible Title V property to HUD 

but noted that the Title V process is time-intensive for several 

reasons. They noted that the Army may report up to 500 properties to 

HUD each quarter and that HUD requires submission of each property 

checklist in hard copy. In addition, U.S. Army officials said that the 

Army has to submit a Title V checklist each time it wants to demolish 

an installation building and that the Title V homeless-assistance 

program-reporting requirements could add about 6 months to the 

demolition process.

Landholding Agencies 

Report Many Properties 

That May Not Be Useful to 

Assist the Homeless, and 

Do Not Report Some 

Properties
 

Page 22 GAO-14-739 Federal Real Property

• DOE officials said that they report to HUD the property they are 

required to report, but believe that completing the Title V reporting 

requirement was not an efficient use of their resources since much of 

the agency’s reported real property has documented deficiencies, 

including environmental contamination requiring remediation, and is 

located within secured boundaries and HUD determines many of 

these unsuitable for homeless assistance. For example, DOE 

properties typically include radiological contaminants commingled with 

other metals and chemicals associated with nuclear research and 

production. In our prior work, DOE also told us that the department 

understood the need to screen excess real property, but that much of 

its portfolio to be disposed had no remaining useful life and was most 

often located within a secure compound.32

• DOI officials said that they are required to––and do––report to HUD 

on numerous small, remotely located properties in National Parks that 

they have decided to dispose. For example, many cabins are not 

accessible by road or may be accessible only by water and only 

during certain times of the year. Officials also told us that in 2013, 73 

properties, mainly small houses on National Park lands were 

determined suitable but for off-site use only, yet the majority of these 

properties were in such poor condition that they could not be moved. 

In addition, DOI officials said that they do not report to HUD real 

property that is only used seasonally as unutilized or underutilized 

because the agency will use the properties again in the following 

season. The Title V homeless assistance program checklist, however, 

expressly asks whether an underutilized property is used seasonally 

(see app. II: HUD Title V Checklist Submitted to Landholding 

Agencies, item 6B).

• EPA officials noted that although some of its laboratories are only 

partially used, they do not report these as underutilized real property 

for HUD’s Title V canvas because they do not believe they are 

required to do so. Rather, EPA’s practice has been to report that it

does not have any underutilized or unutilized properties for each 

quarterly canvass because the space is laboratory space that agency 

officials do not think is practical for homeless assistance programs. 

EPA officials said that they are currently conducting a space utilization 

study for laboratories, and after the study is completed, they will 

 

32 GAO, Federal Real Property: Progress Made Toward Addressing Problems, but 

Underlying Obstacles Continue to Hamper Reform. GAO-07-349 (Washington, D.C: Apr. 

13, 2007).
 

Page 23 GAO-14-739 Federal Real Property

determine whether to report underutilized and unutilized properties 

identified through the study.

• GSA officials told us that as a provider of space to other federal 

agencies, GSA properties are sometimes temporarily or partially 

vacant as the space needs of tenant agencies fluctuate. GSA officials 

said that they do not consider these properties to be underutilized and 

unutilized because the agency plans to use them to house future 

federal tenants. GSA officials said that if they identified underutilized 

and unutilized property in the portfolio that was not to be reported as 

excess, they would report these to HUD’s canvass. However, GSA 

could not identify any such properties that it had reported to HUD in 

the 6 years from 2008 through 2013. Nonetheless, even if GSA

identified a future need for temporarily or partially vacant space, it, like 

other agencies, has two opportunities to inform HUD as to why 

reported properties may not be available: first, the HUD Title V 

checklist asks reporting landholding agencies to provide information 

on any current or anticipated limitations for using the property to assist 

the homeless for a period of one year or more; second, landholding 

agencies are required to provide statements to HUD on the availability 

of properties determined suitable, including reasons why the property 

cannot be declared excess or made available for use to assist the 

homeless.

HUD officials told us that they review and make a suitability determination 

only for those properties reported to them by landholding agencies and 

that they do not have a way of knowing how many properties should be, 

but are not reported. In 2013, the U.S. District Court for the District of 

Columbia noted that many landholding agencies appeared to be “failing to 

fairly and accurately” report Title V homeless assistance program-eligible 

properties as required under both the statute and Order.33

 

33 See Court Order accompanying National Law Center on Homelessness and Poverty v. 

Veterans Admin., 931 F. Supp. 2d 167, 174 (D.D.C. 2013).

Further, the 

court noted that there was a significant discrepancy between the numbers 

of properties reported to HUD under Title V and the much larger number 

of federal properties listed as “excess” or “underutilized” in other 

government reports and surveys. The District Court ordered several steps 

to ensure the proper reporting of properties including that GSA and HUD 

develop a plan for additional improved training programs for landholding 

agencies. To address the court order, GSA and HUD officials told us they 

conducted a joint webinar with HHS in November 2013 for landholding 

agencies.
 

Page 24 GAO-14-739 Federal Real Property

HUD officials told us that they would prefer that agencies not be required 

to report certain types of properties at all because they may not be useful 

to assist the homeless. Requiring agencies to report all properties that fall 

within the four broad categories—excess, surplus, underutilized, and 

unutilized—may not be effective for certain types of properties. While 

there are discretionary elements in HUD’s suitability criteria that are 

applied to properties submitted by the landholding agencies, HUD does 

not have the authority to release agencies from their statutorily required 

reporting of certain types of properties. Excluding certain types of 

properties such as “off-site use only properties” could enable HUD 

officials to focus on the suitable and available properties that may be 

more likely to assist the homeless and could help address issues of 

landholding agencies not reporting certain properties. In 2013, HUD 

proposed a revision to the law that would limit some of the types of 

properties agencies report, such as those that are located in high security 

areas and any building or structure that is made available for off-site use 

only. No action has been taken on that proposal.

Of the 11 homeless assistance providers we interviewed, the eight case 

study providers that acquired property cited benefits from the Title V 

program, such as expanding services and obtaining real property at no 

cost. These successes notwithstanding, the providers identified 

challenges such as locating information on available properties, a 

complex application, difficulty altering the approved use of transferred 

properties, and competing stakeholder interests. For example, although 

HUD reports properties in the Federal Register multiple times a year, and 

USICH provides links to them on its website, many homeless assistance 

providers may be unaware of the availability of properties. This may be 

because homeless assistance stakeholders have said the Federal 

Register is not user-friendly. Further, HUD’s Federal Register reports list 

many of the same properties more than once. This may make listings

even less user-friendly to providers. Homeless assistance providers and 

advocates we interviewed identified a number of actions that could 

address these challenges.

Homeless Assistance 

Providers Expanded 

Services, but Some 

Reported 

Encountering 

Challenges in 

Identifying, Applying 

for, and Using Real 

Property
 

Page 25 GAO-14-739 Federal Real Property

Of the 11 homeless assistance providers we interviewed, the eight case 

study providers that acquired property cited a variety of benefits resulting 

from the acquisition of real property under the Title V homeless 

assistance program.34

For example, the following providers spoke of how they were able to 

expand their programs through the Title V homeless assistance program:

 Representatives of the providers responsible for 

the eight case study properties we reviewed either said that the Title V 

program enabled them to expand their program or service capacity (five 

providers) or acquire real property at no cost (four providers). 

Representatives of two providers cited both types of benefits (see app. V 

for a description of each of the case study properties). 

• The acquisition of the former Boyle Heights Social Security 

Administration Building in Los Angeles enabled Volunteers of America

of Los Angeles (VOALA) to offer services for the homeless, including 

referral services, food and clothing distribution, and job training in Los 

Angeles. VOALA reported serving more than 1,000 persons at this 

facility in 2013.

• The acquisition of an 84-acre portion of the former Homestead Air 

Force Base in Homestead, Florida, enabled Miami-Dade County to 

provide comprehensive services, including emergency shelter, 

transitional housing, and permanent supportive housing, in addition to 

job training, medical care, and clothing, among other services. In 

2013, the Miami-Dade County Homeless Trust reported serving 2,143 

homeless adults and minors at this facility.35

Other providers described how the Title V homeless assistance program 

enabled them to acquire property otherwise not affordable:

• Prior to acquiring four homes located in residential neighborhoods on 

Maryland’s Eastern Shore, Crossroads Community, Inc. rented real 

property to provide rehabilitative services to individuals with mental 

illness in residential settings. Through the Title V homeless assistance 

program, the provider was able to replace rental property at a 

 

34 Altogether, we interviewed 11 homeless assistance providers, including representatives 

from eight case study properties that were acquired under Title V and three providers 

whose applications for property were not approved by HHS.

35 The Miami-Dade County Homeless Trust is an organization within the Miami-Dade 

County government that is responsible for coordinating local homeless systems of care.

The Title V Homeless 

Assistance Program 

Enabled Selected 

Providers to Expand 

Services and Obtain Real 

Property at No Cost
 

Page 26 GAO-14-739 Federal Real Property

relatively low renovation cost with four homes that it acquired through 

the program. In addition, the program property allowed the provider to 

locate clients closer to its other service programs. According to 

Crossroads Community, Inc., the acquisition of the four houses 

currently saves the organization about $62,000 in rent on an annual 

basis.

• According to a representative of the City of Redmond, Washington, 

the greatest benefit of the Title V homeless assistance program lies in 

providing opportunities for non-profit organizations to acquire real 

property at minimal or no cost. The city acquired at no cost about half 

of a 10.2 acre site under the program that included 16 housing units 

formerly used to house U.S. Coast Guard personnel. The City of 

Redmond purchased the remainder of the real property through a 

negotiated sale with GSA. From the outset, the city planned to 

redevelop the Title V homeless assistance program portion of the real 

property into a larger facility to assist the homeless and 1-acre park, 

and develop the non-Title V portion into affordable housing units. 

Leveraging its resources, the city redeveloped the Title V homeless 

assistance program portion of the real property with 59 housing units 

that provided emergency, transitional, and permanent supportive 

housing for 319 households in 2013.

In addition to enabling homeless assistance providers to expand their 

services and obtain property they would likely have to pay for otherwise, 

the National Law Center stated that the Title V homeless assistance 

program also benefits the taxpayers by repurposing and reusing real 

property no longer needed by the federal government, helping the 

government––and by extension, the taxpayers––avoid and eliminate the 

maintenance and operation costs of retaining these properties.

These successes notwithstanding, homeless assistance providers we 

interviewed identified challenges such as locating information on available 

properties, a complicated application, difficulty altering the approved use 

of transferred properties, and competing stakeholder interests.

Although HUD reports regularly in the Federal Register for the purpose of 

informing homeless assistance providers about properties, among the 11 

homeless assistance providers we interviewed, one said it was initially 

unaware of the program or the availability of real property in its area, and 

eight told us they eventually learned about the program through third 

Selected Homeless 

Assistance Providers 

Reported a Range of 

Challenges in Identifying, 

Acquiring, and Using 

Federal Real Property

Most Selected Homeless 

Assistance Providers Were 

Unaware of Federal Register 

Notices
 

Page 27 GAO-14-739 Federal Real Property

parties rather than through the Federal Register. Title V requires HUD to 

publish, in the Federal Register, a list of real property it has evaluated for 

suitability. This occurs multiple times each year: four quarterly reports and 

a summary annual report. In addition, to comply with the 1988 court 

order, as modified in 1993, HUD publishes a weekly notice in the Federal 

Register of properties that are suitable and available, unavailable, and 

unsuitable (see table 5).

Table 5: Department of Housing and Urban Development’s (HUD) Federal Register Reporting Requirements

Type of report

Time frame/ publication 

date Purpose Source authority

Reporting (general) No later than 15 days after 

receiving reports from 

landholding agencies

Publish suitability determination of 

properties submitted to HUD by 

landholding agencies

42 U.S.C § 11411 (c)(1)(A). 

Two comprehensive 

quarterly reports 

End of 1st quarter – 

January 1 and

End of the 3rd quarter – 

July 1

Publish newly reviewed properties as 

well as previously reported properties 

that may or may not have changes

42 U.S.C. § 11411 (c)(1)(A); 

National Law Center on 

Homelessness and Poverty v. 

Veterans Admin., 819 F. Supp. 69

(D.D.C. 1993).

Two supplemental 

quarterly reports 

End of the 2nd quarter and

End of the 4th quarter – 

October 1

Publish only newly reviewed properties 

from the previous quarter

42 U.S.C. § 11411 (c)(1)(A); 

National Law Center on 

Homelessness and Poverty v. 

Veterans Admin., 819 F. Supp. 69

(D.D.C. 1993).

Annual report Previous calendar 

year/around February 15

Publish all the properties identified as 

suitable/available and 

suitable/unavailable in the prior calendar 

year in addition to suitable properties 

from prior years that were republished 

and may still be available or for which the 

availability status has changed

42 U.S.C § 11411 (c)(1)(D), 

(c)(4)(B). 

Source: GAO Analysis of 42 U.S.C §11411, National Law Center on Homelessness and Poverty v. Veterans Admin., 819 F. Supp. 69 (D.D.C. 1993) and HUD documents. | GAO-14-739

HUD shares the Federal Register notices of suitable and available 

properties with the U.S. Interagency Council on Homelessness (USICH) 

multiple times a year, and USICH provides links to the list on its agency 

website. Nonetheless, according to national homeless advocates, many 

providers remain unaware of the availability of properties. For example, 

the National Law Center reported that despite the Title V homeless 

assistance program’s having been in existence for 25 years, too few local 

government and homeless providers are aware that they are eligible to 
 

Page 28 GAO-14-739 Federal Real Property

receive property free.36

In addition, HUD’s Federal Register reports list many of the same 

properties more than once, as required, and that may make listings more

confusing and less useful for providers to use. For example, for the period 

from 2008 through 2013, 59 percent of the properties appeared in more 

than one annual report. Because, under Title V, suitable properties must 

be reported on an ongoing basis until they are disposed of––regardless of 

their availability status––HUD reports some properties in the Federal 

Register multiple times, in some cases over several years, even though 

homeless assistance providers have not expressed interest in these 

properties. Our analysis of HUD’s annual reports for calendar years 2008 

through 2013 found that of the 1,677 properties reported over the 6 years, 

982 (59 percent) appeared in more than one annual report and 288 (17 

percent) appeared in each of the six annual reports. For example, we 

found one property in Baltimore, Maryland, that was listed in three annual 

reports from 2011 through 2013. In another case in Macon, Alabama, a 

property was listed in HUD’s annual reports each year from 2008 through 

2011. In the past, some in Congress and the executive branch have 

expressed concern about reporting requirements; the basic concern has 

been that some requirements result in reports that may be unnecessarily 

burdensome to produce or, in some instances, not very useful. Our prior 

work at other federal agencies has reviewed reporting requirements, the 

limited usefulness of some reports, duplicative reporting, and has found 

that less frequent reporting could allow agencies to continue to fulfill their 

responsibilities.

Moreover, a representative from the National 

Coalition for the Homeless told us that in general, homeless assistance 

providers do not have the staff resources to check the Federal Register

consistently.

37

HUD officials told us that, instead of publishing suitable and available 

properties in the Federal Register, they believe it would be more efficient 

 

36 National Law Center on Homelessness and Poverty. This Land Is Your Land: How 

Surplus Federal Property Can Prevent and End Homelessness (Washington, D.C.: 

October 2013). 

37 See for example, GAO, Video Marketplace: Competition Is Evolving, and Government 

Reporting Should Be Reevaluated. GAO-13-576 (Washington, D.C.: June 25, 2013), and 

GAO, K-12 Education: Selected States and School Districts Cited Numerous Federal 

Requirements As Burdensome, While Recognizing Some Benefits. GAO-12-672 

(Washington, D.C.: June 27, 2012). 
 

Page 29 GAO-14-739 Federal Real Property

and beneficial to homeless providers to publish the information on their 

Community Planning and Development “OneCPD” website, which serves 

as a resource exchange and provides technical assistance to 

stakeholders for a wide variety of programs including the Title V homeless 

assistance program. Further, both the National Law Center and the 

National Coalition for the Homeless suggested that available properties 

should be listed on the Internet in an easily accessible format, unlike the 

Federal Register, which they said is not user-friendly. Some stakeholders 

suggested that the federal government could make information more 

accessible by establishing a single web-based source of information on 

the program. However, if HUD were to report Title V properties on its 

OneCPD website, this would add to HUD’s other reporting requirements if 

the Title V reporting requirements remained unchanged, and HUD 

officials do not believe they have the resources to do both.38

Five of the homeless assistance providers we interviewed noted 

challenges with the application. Two providers reported that completing 

the application required additional resources and was time consuming, 

particularly in obtaining technical reports such as environmental 

assessments. For example, one organization hired a contractor to 

prepare the application, which was nearly 300 pages long and required 

extensive technical documentation. In another case, the representative 

said that the application process was time consuming because of the 

large volume of supporting documentation required. Among the homeless 

assistance providers we interviewed, one reported obtaining the 

environmental reports from GSA, while others paid a consultant to obtain 

the documentation or used their resources to collect it for the purpose of 

the application. Another provider noted that GSA responded slowly to 

requests for both access to the site and for documentation, such as site 

blueprints. According to this representative, GSA took nearly 60 days of 

the 90-day application period to provide access and documentation that 

had been requested at the beginning of the application process.39

 

38 HUD has taken steps to help homeless assistance providers learn about properties 

such as a listserv and a call-in line that providers can use to obtain information about 

properties.

Based 

on our work, we believe the large difference, discussed above, between 

the number of notices of interest and the number of applications may be, 

39 According to the implementing regulations, HHS is to assist applicants in obtaining any 

pertinent environmental information in GSA, HUD or any other landholding agency’s 

possession. 45 C.F.R. §12a.9(b)(8).

Complex Application
 

Page 30 GAO-14-739 Federal Real Property

in part, due to the complexity and resources required to complete the 

application within a 90-day period. These case study results are 

consistent with the National Law Center’s findings, which state that the 

application is lengthy and cumbersome, making it difficult for a homeless 

assistance provider to complete in the short time frame imposed under 

the law. In addition, the application calls for homeless assistance 

providers to collect information that is already in the government’s 

possession, such as a description of the easements on the property.40

HHS, as the agency responsible for ensuring that homeless providers use 

the transferred real properties according to the approved application, also 

approves any changes to the original program of use for the properties. 

Two of the selected case study providers told us that they found it difficult 

to alter the original program of use for their properties. According to the 

two providers, the needs of the homeless clientele they serve had 

changed since their applications were approved. For example, one 

provider told us that the homeless population the organization currently 

serves largely consists of persons recently released from incarceration 

and, unlike the population it served when the property was first 

transferred in 2002, is perhaps better educated than the previous 

population. This provider stated that due to the changing population, 

workforce training has become more of a need than it was in the past. 

The provider noted that it took many letters to convince HHS that 

workforce training was a necessary part of the organization’s homeless 

assistance. Another provider obtained a property for use as transitional 

housing for mentally ill homeless adults and wanted to alter the program 

to provide permanent housing to this population; a representative for that 

provider told us that the organization has thus far decided not to pursue 

its request to HHS because it understands that it would have to restart the 

The HHS Title V official told us that several years ago, the Department 

modified the application packet to address some of these stakeholder 

concerns. Two homeless assistance providers we interviewed suggested 

that HHS consider providing examples of model applications on a public 

website. HHS officials told us that they believe posting examples of 

successful applications on the Internet may lead to homeless assistance 

applicants using examples that may not be relevant to their particular 

circumstances.

 

40 National Law Center on Homelessness and Poverty. This Land Is Your Land: How 

Surplus Federal Property Can Prevent and End Homelessness (Washington, D.C.: 

October 2013).

Difficulty Altering Approved 

Real Property’s Use to Meet 

Changing Client Needs
 

Page 31 GAO-14-739 Federal Real Property

application process.41 HHS Title V homeless assistance program 

representatives told us, that while much of the information requested for 

the original application would need to be resubmitted, the provider would 

not need to resubmit a full application.42

Our literature review and case study interviews found that homeless 

assistance organizations often reported meeting resistance from local 

interests and groups when attempting to acquire federal properties. 

Further, USICH’s 2011 annual report noted that, in some cases, local 

opposition to the use of the property by homeless providers has caused 

them to withdraw their applications to the Title V homeless assistance 

program.43

• One case study provider, whose real property is located in an 

industrial, non-residential area, told us that the organization changed 

its original plan from providing shelter services to providing job 

training and social services instead of shelter in response to local 

opposition from neighboring businesses.

Two of the homeless providers we interviewed for our case 

studies reported meeting strong community opposition, which, according 

to one provider, related to concerns about safety, number of homeless 

assistance facilities within a given area, and the impact on real property 

values, for example: 

• Another case study provider encountered strong local opposition to its 

proposal to use the four residential properties as locations for clients 

undergoing mental health rehabilitation. The provider said its

organization mitigated the resistance over the course of a year by 

 

41 HHS concluded in 1992 that long-term housing did not constitute an appropriate use of 

property authorized under Title V and subsequently adopted the HUD standard, limiting 

occupancy to 24 months. However, HHS revised this policy effective September 1, 2006, 

to include permanent supportive housing, i.e., long-term, affordable housing that is linked 

to appropriate supportive health and social services that enable homeless individuals and 

homeless families with disabilities to maintain housing. 71 Fed. Reg.38882. (July 10, 

2006). 

42 HHS officials noted that it requires the grantees wishing to change their approved 

program to address similar questions for the change as were required in the initial 

application. For example, the grantee must identify the need for the revised program and 

the funding available to implement the change. This information is used by HHS to make a 

determination on the need for the revised program within the community and if it is 

sustainable for the duration of the deed or lease.

43 United States Interagency Council on Homelessness. Opening Doors: Appendix: 

Programs for People Experiencing Homelessness 2011 (Washington, D.C.: 2011). 

Competing Stakeholder 

Interests
 

Page 32 GAO-14-739 Federal Real Property

holding multiple informational community meetings and conducting a 

workshop on removing the stigma associated with mental illness and 

homelessness at a local community college. Since the program has 

been in place, the organization has not experienced any further 

opposition to the program.

• Another case study provider described how the organization 

successfully addressed and minimized the potential for local 

opposition. In this case, the City of Redmond, Washington, worked 

with an inter-local government organization– A Regional Coalition for 

Housing (ARCH)–in acquiring the Title V real property. The City and 

ARCH then worked with a consortium of homeless providers in 

developing a homeless assistance program. Anticipating concerns, 

particularly from nearby residents, ARCH and the city staff reached 

out to the neighborhood to ensure that neighborhood interests were 

represented during the planning phase of the program, including a 

series of meetings.

Our prior work has found similar competing stakeholder interests. For 

example, state and local governments, business interests in the 

communities where the assets are located, private sector construction 

and leasing firms, various advocacy groups, and the public in general 

have an interest in how the federal government carries out its real 

property management practices.44 We have raised this concern as an 

underlying problem in our biennial high-risk area updates on federal real 

property.45 In addition, we recommended to the Office of Management 

and Budget (OMB) in 2012, the development of a cohesive national 

strategy for managing federal excess and underutilized real property that 

would also address competing stakeholder interests. OMB did not directly 

state whether it agreed or disagreed with our recommendation.46

All four federal agencies—GSA, HHS, HUD and USICH—bear some 

responsibility for addressing challenges homeless assistance providers 

face with the Title V homeless assistance program, such as identifying 

and acquiring properties and developing a web-based source of 

Moreover, OMB has not taken action on our recommendation as of the 

time of this report.

 

44 GAO-07-349. 

45 GAO-13-283. 

46 GAO-12-645. 
 

Page 33 GAO-14-739 Federal Real Property

information on the program. By collaborating to address these concerns, 

the federal agencies could provide information that would be more useful 

to homeless providers and thereby more effectively manage agency 

resources to contribute to the goal to end homelessness. Our prior work 

has found that many of the meaningful results that the federal 

government seeks to achieve require the coordinated efforts of more than 

one federal agency and often more than one sector and level of 

government.47 We have reported about the importance of collaboration 

among federal agencies for many years. In its 2011 annual report, USICH 

noted that the Title V homeless assistance program process for 

identifying properties, determining suitability, determining availability by 

landholding agencies, and leasing or deeding surplus properties involves 

at least three federal agencies and can appear quite confusing and 

cumbersome to homeless providers.48 USICH is composed of 

representatives from 19 federal agencies—including GSA, HHS, and 

HUD. While not having the authority to ensure compliance, USICH 

monitors, evaluates, and recommends improvements in federal and state 

homeless assistance programs and is required by law to meet at least 

four times a year. USICH is supported by the Council Policy Group, which 

provides a regular forum for coordinating policies and programs, 

collecting data, developing special initiatives, and preparing 

recommendations for consideration by USICH members. Unlike other 

interagency groups, although USICH is a very small agency, it receives 

an appropriation from Congress and employs full-time staff in 

Washington, D.C., and five regional posts.49 As such, resources and a 

process for addressing some of the stakeholder concerns are already in 

place.

HUD has evaluated at least 40,000 underused, unused, and unneeded 

federal real property assets for the Title V homeless assistance program 

since it began in 1987. However, only a small fraction of the properties 

HUD determined suitable and that were available have been transferred 

 

47 GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). 

48 United States Interagency Council on Homelessness. Opening Doors: Appendix: 

Programs for People Experiencing Homelessness 2011 (Washington, D.C.: 2011).

49 GAO, Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014).

Conclusion
 

Page 34 GAO-14-739 Federal Real Property

to homeless assistance providers since the program’s inception—likely 

because the majority of the properties were not useful to them. The 81 

active properties transferred have provided needed services to the 

homeless population across the nation. While HUD lists information on 

the properties it evaluates in the Federal Register multiple times each 

year, as required by law, many of the listings are duplicative, and many 

service providers are not even aware of the Title V homeless assistance 

program. Given that all underutilized, unutilized, excess, and surplus 

federal real property is subject to Title V homeless assistance program 

reporting requirements––including buildings, land, or both, without regard 

to location, size, or practicality—the scope of properties reported (with 

particular attention to the usefulness of the property and the frequency of 

reporting) is crucial to helping HUD make the program more useful to 

homeless assistance providers. In addition, a reliable, searchable 

electronic database of the properties HUD has reviewed would improve 

HUD’s ability to provide information to meet required reporting needs. 

While homeless assistance providers benefitted from obtaining federal 

real property otherwise not affordable to them and expanded their 

services, addressing the challenges they face in identifying properties 

would improve program effectiveness. Collective efforts by all four 

responsible federal agencies—GSA, HHS, HUD, and USICH—could help 

to address these concerns. Without these changes, the Title V homeless 

assistance program may not be making the best use of its resources to 

make progress toward ending homelessness in the nation.

To ensure that properties determined as suitable and available are more 

likely to be practical for homeless assistance and that Federal Register

reporting is not redundant, Congress should revisit the scope of 

properties to be reported to HUD with respect to the types of properties 

that may be less likely to be useful to assist the homeless and the 

frequency of Federal Register reporting.

• To improve HUD’s database on Title V homeless assistance 

properties, HUD should modify its existing database or create an 

electronic, searchable database to meet reporting needs to the extent 

that the benefits outweigh the costs.

• HUD, GSA, HHS, and USICH should work together to address the 

challenges that homeless assistance providers face with the Title V 

homeless assistance program by

Matter for 

Congressional 

Consideration

Recommendations for 

Executive Action
 

Page 35 GAO-14-739 Federal Real Property

• identifying what kinds of properties are most practical for homeless

assistance, and

• developing a web-based source of information on the program for 

homeless assistance providers.

We provided a draft of this report for review and comment to the four 

agencies with a role in administering the Title V homeless assistance 

program: GSA, HHS, HUD, and USICH. We also provided a draft of this 

report to the landholding agencies we included in our review: the EPA,

the DOD service branches—the U.S. Air Force, the U.S. Army and the 

U.S. Navy––DOE and DOI. We received written comments from GSA, 

HHS, and USICH, which are summarized below and reprinted in 

appendixes of this report. HUD’s agency liaison provided comments via 

e-mail on September 18, 2014, which are summarized below. In addition, 

GSA, HHS, HUD, the U.S. Army and the DOE provided technical 

comments, which we incorporated as appropriate. The EPA, U.S. Air 

Force, U.S. Navy, and DOI did not provide any comments. 

GSA concurred with the findings of the report and the recommendation 

that it work with HHS, HUD, and USICH to address the challenges that 

homeless assistance providers face by identifying what kinds of 

properties are most practical for homeless assistance and developing a 

web-based source of information on the program for providers. GSA

stated that it will continue to work with both HUD and HHS on this effort. 

GSA noted that it has taken steps to enhance its website with additional 

information and resources about the Title V homeless assistance program 

and provide additional information about how to locate available 

properties. The agency stated that it has also provided the opportunity for 

interested homeless assistance providers to subscribe to receive 

automatic e-mail notifications as properties are posted to its website. 

These are positive steps to provide additional information on the 

homeless assistance program. GSA’s comments can be found in 

appendix VI. 

HHS did not concur with our recommendation that it should work together 

with GSA, HUD, and USICH to address the challenges that homeless 

providers face by identifying what kinds of properties are most practical 

for homeless assistance. HHS stated that this was outside of the scope of 

its legal authority and noted that under the authorizing statute and the 

Agency Comments

and Our Evaluation
 

Page 36 GAO-14-739 Federal Real Property

regulation, HUD, is solely authorized to identify suitable property and 

apply the suitability criteria to properties reported by landholding agencies 

pursuant to Title V requirements. We recognize that under the statute,

50

HUD also concurred with the report’s overall findings, and with the 

recommendation that it modify its database or create a searchable, 

electronic database on the Title V homeless assistance properties to 

meet its reporting needs. HUD officials noted that its proposed legislative 

changes included the development of an improved database that would 

be searchable and would allow HUD stakeholders to view profiles of 

those properties that are suitable and available to be used to assist the 

homeless. HUD also concurred with the recommendation that it work 

together with GSA, HHS and USICH to address challenges providers face 

with identifying the kinds of properties that are most practical for 

homeless assistance, and to develop a web-based source of information 

on the program. HUD noted that it had already proposed legislative 

HUD is solely authorized to make determinations regarding whether 

properties are suitable for use to assist the homeless. However, the 

McKinney-Vento Homeless Assistance Act, as amended, required GSA, 

HHS, and HUD to promulgate implementing regulations. In response, 

GSA, HHS, and HUD promulgated a joint interim final rule that set out, 

among other things, the criteria to be applied by HUD in making its 

suitability determinations. The interim final rule putting the joint regulation 

in place explained that the suitability criteria have been developed with 

the intent of excluding only those properties that are clearly unsuitable for 

use to assist the homeless. The issuing agencies of the joint rule may

revisit the scope of such regulatory exclusions of clearly unsuitable 

property to assess if they merit adjustment. Given that the rule was a joint 

issuance by GSA, HHS, and HUD, our recommendation that the agencies 

work together to identify what kinds of properties are most practical for 

homeless assistance is directed to the four agencies with responsibility 

for implementing the program. HHS concurred with the second part of the 

recommendation that it should work together with GSA, HUD, and USICH 

to develop a web-based source of information on the program for 

homeless assistance providers, and noted that it is in the process of 

refurbishing its federal real property assistance website and will consult 

with the other three agencies to discuss options relating to web-based 

sources of information on the Title V homeless assistance program. 

HHS’s comments can be found in appendix VII. 

 

50 42 U.S.C. §11411.
 

Page 37 GAO-14-739 Federal Real Property

changes to create a web-based source of information on available 

properties in place of publishing properties in the Federal Register. 

Although we support a legislative change to address certain aspects of 

the law, as stated in our Matter for Congressional Consideration, our 

recommendations to HUD are not contingent upon legislative changes.

As noted in our report, because HUD uses its Title V database primarily 

for generating listings for the Federal Register, it has not assessed the 

extent to which the benefits of modifying it to generate electronic reports, 

or developing a database to do so, would outweigh the costs. In addition, 

as one of the four federal agencies responsible for the program, HUD 

shares responsibility for addressing the challenges that homeless 

assistance providers face, such as identifying and acquiring properties 

and developing a web-based source of information on the program. 

USICH agreed that the scope of properties that agencies are required to 

report under Title V include large numbers of properties that could not 

viably be used for homeless assistance. However, it did not agree with 

our recommendation that it work together with GSA, HHS, and HUD to 

identify the kinds of properties that are most practical for homeless 

assistance. USICH stated that improving the identification of properties 

that are practical for homeless assistance cannot occur through 

collaboration alone and that a legislative fix is an essential prerequisite. 

We continue to believe that, as one of the agencies responsible for 

implementing the Title V homeless assistance program, USICH shares 

responsibility for addressing challenges homeless assistance providers 

face, such as identifying and acquiring properties. As noted in our report, 

by collaborating to address these concerns, the federal agencies could 

provide information that would be more useful to homeless providers. 

USICH concurred with the recommendation on developing a web-based 

source of information on the program for homeless assistance providers 

and stated that it may be beneficial for disseminating information on 

available federal real properties to interested stakeholders. USICH’s 

comments can be found in appendix VIII. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Administrators of the 

Environmental Protection Agency and the General Services

Administration; the Executive Director of the U.S. Interagency Council on 

Homelessness; and the Secretaries of Defense, Energy, Health and 

Human Services, Housing and Urban Development, and the Interior. We 

are also sending copies of this report to the House Committee on 
 

Page 38 GAO-14-739 Federal Real Property

Oversight and Government Reform. In addition, this report will be 

available at no charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or wised@gao.gov. Contact points for our Office of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix IX.

David J. Wise

Director

Physical Infrastructure Issues
Appendix I: Scope and Methodology

Page 39 GAO-14-739 Federal Real Property

To determine what is known about the identification and transfer of 

federal real properties for homeless assistance under Title V, we 

reviewed the requirements of Title V of the Act as they apply to the 

General Services Administration (GSA), the Department of Health and 

Human Services (HHS), the Department of Housing and Urban

Development (HUD), and the United States Interagency Council on 

Homelessness (USICH). We reviewed these agencies’ internal policies, 

procedures and other documents on how they implement the 

requirements of the programs. HUD does not maintain electronic records 

of all the properties reported under Title V since the inception of the 

program. Thus, due to the lack of available data in a format that allowed 

analysis, HUD provided us with estimates of the number of underutilized, 

unutilized, excess, and surplus properties reported by landholding 

agencies and the number that HUD determined to be suitable and were 

available for homeless use from the early 1990s through March 31, 2014. 

These estimates are based on the number of properties that were entered 

into HUD’s Title V database, developed in the early 1990s, several years 

after the McKinney-Vento Act was implemented. Further, HUD officials 

are not certain of the extent to which the database includes the Title V 

homeless assistance program properties reported prior to its creation. 

Due to the lack of available data in a format conducive to analysis, we 

could not verify the reliability of these estimates. We interviewed officials 

from HUD about how the estimates were derived and could not verify the 

reliability of these estimates. To assess the reliability of these estimates, 

we interviewed officials from HUD about how the estimates were derived 

and determined that the information provided by the agency provides a 

reasonable basis, with caveats, for reporting the number of properties that 

have been screened and published as suitable and available. In addition, 

to determine the number of properties reported in these categories and 

the number and percentage of these that were available for “off-site use 

only,” we analyzed HUD annual reports of suitable/available and 

suitable/unavailable properties for years 2008 through 2013. This time

frame was selected to include the 5 years prior to the audit, and when 

HUD’s annual report for 2013 became available we added it to the 

analysis to include the most recent information. Our analysis of the 

Federal Register notices relied on identifying properties by the unique 

Property Identification (ID) number published with each property listing. 

We also obtained from HHS documents and data on the number of 

notices of interest and applications received for federal real property 

made available for homeless assistance and on the number, location, and 

use of properties transferred from the program’s inception in 1987 

through March 31, 2014—the date of the most recently available 

information.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 40 GAO-14-739 Federal Real Property

To assess the reliability of these data, we interviewed officials from HHS 

about how the data are collected and maintained and the steps taken by 

the agency to ensure the completeness of these data. Based on this 

discussion, we determined that the data were sufficiently reliable for the 

purposes of this report. In order to assess the number of properties that 

received notices of interest and applications from interested providers, we 

also manually reviewed data on notices of interest and applications 

received to identify potential duplicate properties by GSA number, 

property name, location, and description. To understand how federal 

landholding agencies identify and report real property to HUD pursuant to 

the Act’s requirements, we selected nine landholding agencies to include 

a range of size among real property portfolios of land and buildings. 

These agencies were GSA; HHS; the Departments of Defense’s U.S. 

Army, U.S. Air Force, and U.S. Navy; the Departments of Energy; the 

Interior and Veterans Affairs;

1 and the Environmental Protection Agency.

When combined, these nine landholding agencies accounted for almost 

90 percent of the buildings held by the federal government in 2012.2

 We 

collected documents from these agencies to understand how each 

agency manages and fulfills its reporting requirements under Title V, the 

extent to which it collaborates with other agencies, and to obtain views on 

how Title V requirements impact the federal real property disposal 

process. We interviewed agency officials from the GSA, HHS, and HUD 

to understand how they process properties reported under Title V 

homeless assistance program requirements, and we interviewed officials 

from USICH to understand its role with Title V. We also interviewed 

agency officials from the nine landholding agencies to obtain their views 

on how they meet the Act’s requirements and the impact of those 

requirements on each agencies disposal process.3

To determine the benefits and challenges selected homeless assistance 

providers and national advocacy organizations reported in identifying, 

acquiring and using federal real property, and the potential actions that 

 

1 After preliminary audit work, we did not continue our work at VA because we learned 

that very little of VA’s property becomes available for Title V purposes.

2 According HUD officials, HUD is not a landholding agency.

3 We excluded from this report facilities on military bases closed after 1994 and subject to 

the provisions of the Base Closure Community Redevelopment and Homeless Assistance 

Act of 1994 (Redevelopment Act) (Pub. L. No.103-421, 108 Stat. 4346) but are reviewing 

implementation of the Act’s provisions separately and will report on this in 2015.
Appendix I: Scope and Methodology

Page 41 GAO-14-739 Federal Real Property

could help address those challenges, we selected eight homeless 

assistance organizations that acquired federal real property under the 

program. The providers were: the City of Redmond, Washington; 

Crossroads Community, Inc.; Samaritan House; The Miami-Dade County 

Homeless Trust; Third Way Center; Urban Renewal Corporation; 

Veterans Coming Home/New Life Evangelistic Center; and Volunteers of 

America, Los Angeles. We made our selection using criteria such as the 

size of the real property acquired under the program, the services 

provided, geographic distribution, range of experiences with the Title V 

program, and suggestions from agencies and homeless advocacy 

organizations (GSA, HUD, HHS, USICH, the National Law Center on 

Homelessness and Poverty, and the National Coalition for the Homeless). 

In addition, to assist the selection, we also used information from news 

reports and our literature review to identify high-profile properties. We 

interviewed representatives from each of the selected organizations, 

reviewed their annual utilization reports, and conducted site visits to two 

properties transferred under Title V. While information from case studies 

is not generalizable, the perspectives of the homeless service providers 

provided us with examples of the benefits and challenges associated with 

the program. Further, to gain additional perspectives on experiences with 

the federal agencies and the application process, and identify potential 

improvements to the process, we convened a virtual discussion panel 

comprised of representatives from homeless assistance organizations 

whose Title V applications were not approved. We selected and recruited 

seven organizations, of which three agreed to participate in the panel.4

 

4 Representative of the other four organizations were unable to participate because of 

unanticipated schedule conflicts. 

These organizations were selected from HHS’s Title V homeless 

assistance program applicant data from 2006 through 2013 based on 

their geographic locations and proposed use of the properties. We 

selected the particular time frame to ensure that the information provided 

was reasonably up to date. Since the virtual discussion panel was 

selected using a non-probability sample of homeless assistance 

applicants whose Title V applications were declined by HHS, like the case 

studies, their experiences cannot be generalized to all homeless service 

providers. In addition, we reviewed the reports and interviewed 

representatives of two national advocacy organizations—the National 

Law Center on Homelessness and Poverty and the National Coalition for 

the Homeless.
Appendix I: Scope and Methodology

Page 42 GAO-14-739 Federal Real Property

We conducted this performance audit from September 2013 to 

September 2014 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD

Page 43 GAO-14-739 Federal Real Property

Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD
Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD

Page 44 GAO-14-739 Federal Real Property
Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD

Page 45 GAO-14-739 Federal Real Property
Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD

Page 46 GAO-14-739 Federal Real Property
Appendix II: Sample Title V Checklist 

Submitted by Landholding Agencies to HUD

Page 47 GAO-14-739 Federal Real Property
Appendix III: List of Landholding Agencies 

HUD Canvasses for Title V

Page 48 GAO-14-739 Federal Real Property

1. Central Intelligence Agency

2. Department of Commerce

3. Department of Agriculture

4. Department of the Air Force

5. Department of the Army

6. Department of the Navy

7. Department of Education

8. Department of Energy

9. Department of the Interior

10. Department of Justice

11. Department of Health and Human Services

12. Department of Labor

13. Department of State

14. Department of Transportation

15. Department of the Treasury

16. Department of Veterans Affairs

17. Environmental Protection Agency

18. Federal Communications Commission

19. Federal Emergency Management Agency

20. General Services Administration

21. International Broadcasting Bureau of the Broadcasting Board of 

Governors

22. National Aeronautics and Space Administration

23. National Science Foundation

24. U.S. Army Corps of Engineers

25. U.S. Coast Guard

Appendix III: List of Landholding Agencies 

HUD Canvasses for Title V
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 49 GAO-14-739 Federal Real Property

As of March 2014, 81 Title V properties were currently in use by 

homeless assistance providers across the country to provide a range of 

homeless assistance services. The table below presents the services 

provided at each location by state.

Table 6: Services Provided at 81 Active Properties Transferred under Title V, by State

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Catholic Social 

Services, Inc., 

Anchorage, AK

● ● 2

Tundra 

Women’s 

Coalition, 

Bethel, AK

● 1 

Tundra 

Women’s 

Coalition, 

Bethel, AK

● 1 

Salvation Army, 

Benton, AR

● ● 2 

The Family 

Center, Inc., 

Helena, AR.

● 1 

Quapaw House, 

Inc., Hot 

Springs, AR

● ● ● 3 

Our House, Inc., 

Little Rock, AR

● ● ● ● 4 

Esperanza en 

Escalante, 

Tucson, AZ

● ● ● 3 

House of 

Refuge, Inc., 

Mesa, AZ

● ● 2

House of 

Refuge East, 

Mesa, AZ

● ● 2 

Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 50 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

The Community 

Housing 

Partnership, 

Inc., Mesa, AZ

● ● ● ● 4 

Community 

Social Model 

Advocates, Inc., 

Atwater, CA

● ● ● 3 

Community 

Social Model 

Advocates, Inc., 

Atwater, CA

● 1 

Salvation Army, 

Bell, CA

● ● ● ● ● ● 6 

Shelter 

Partnership, Inc, 

Bell, CA

● 1 

Salvation Army 

Southern 

California 

Division, Los 

Angeles, CA

● ● 2 

Volunteers of 

America of L.A.,

Los Angeles, 

CA

● ● 2

Veterans 

Transition 

Center of 

Monterey,

Marina, CA

● 1 

Housing 

Authority of the 

County of 

Monterey, 

Monterey, CA

● 1

Housing 

Authority of the 

County of 

Monterey, 

Monterey, CA

● ● ● 3 
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 51 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Interim, Inc., 

Monterey, CA

● ● ● 3 

Shelter 

Outreach Plus, 

Monterey, CA

● ● ● 3 

Shelter Plus, 

Monterey, CA

● ● ● 3 

Vietnam 

Veterans of 

Monterey 

County,

Monterey, CA

● ● ● 3 

County of 

Sacramento, 

Rancho 

Cordova, CA

● ● 2 

Vietnam 

Veterans of 

California, Inc.,

Redding, CA

● 1 

California 

Emergency 

Food Link, 

Sacramento, CA

● 1 

Grace Apostolic 

Church, San 

Bernardino, CA

● 1 

Grace Apostolic 

Church, San 

Bernardino, CA

● ● 2 

Third Way 

Center, Denver, 

CO

● 1 

Community for 

Creative 

Nonviolence, 

Inc., 

Washington, 

D.C.

● 1 
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 52 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Metropolitan 

Dade County 

Government, 

Homestead, FL

● ● ● ● ● 5 

Mount Olive 

Community 

Outreach 

Center, Inc., 

Albany, GA

● ● 2 

Growing Home, 

Inc., Miller 

Township, IL

● 1 

5020 State 

Street, LLC, St. 

Louis, IL

● ● ● 3 

North CentralFlint Hill Agency 

on Aging, 

Manhattan, KS

● ● ● 3 

Aftercare 

Ministries, Inc., 

Alexandria, LA

● 1 

Monroe Area 

Guidance 

Center, Monroe, 

LA

● ● 2

City of Lynn, 

Lynn, MA

● ● 2 

Crossroads 

Community, 

Inc., 

Chestertown, 

MA

● 1

Health and 

Education 

Services, Inc., 

Topsfield, MA

● ● 2 

Vietnam 

Veterans 

Workshop, Inc.,

Boston, MA

● ● ● ● ● 5
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 53 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Advocates for 

Homeless 

Families, 

Frederick, MD

● ● 2 

Catholic 

Charities of the 

Archdiocese of 

Washington, 

Inc., Waldorf, 

MD

● ● ● 3 

City of Bangor, 

Bangor, ME

● 1

AMHC 

Facilities, Inc., 

Caribou, ME

● ● ● 3 

Homeworkers 

Organized for 

More 

Employment, 

Ellsworth, ME

● 1 

Pontiac Rescue 

Mission, 

Pontiac, MI

● ● ● ● 4 

Salvation Army, 

Warren, MI

● ● ● 3 

Salvation Army, 

Duluth, MN

● ● ● 3 

Economic 

Security Corp. 

of Southwest 

Area, Joplin, 

MO

● ● 2 

New Life 

Evangelistic 

Center, Inc., 

Springfield, MO

● ● 2 

Human 

Resource 

Development 

Council, Inc., 

Bozeman, MT

● ● ● ● 4 
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 54 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Samaritan 

House, Inc., 

Kalispell, MT

● ● ● 3 

Housing 

Authority of the 

County of 

Scottsbluff, NE, 

Scottsbluff, NE

● ● ● 3 

Middlesex 

Interfaith 

Partners with 

the Homeless, 

Edison, NJ

● ● ● 3 

Urban Renewal 

Corp., Kearny, 

NJ

● ● 2 

New Day, Inc., 

Albuquerque, 

NM

● ● ● 3

OvercomingLove Ministries, 

Brooklyn, NY

● ● 2 

Paterson 

Coalition for 

Housing, Inc., 

Clifton, NY

● 1

Rockland 

Housing Action 

Coalition, Inc., 

Tappan, NY

● 1 

Neighbors of 

Watertown, Inc., 

Watertown, NY

● ● ● 3 

United Christian 

Ministries, 

Lawrenceville, 

PA 

● ● ● 3 

Community 

Mental Health 

Service 

Properties, Inc., 

Phoenixville, PA

● ● 2
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 55 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

Community 

Mental Health 

Services. Inc., 

West Chester, 

PA 

● ● 2 

Interfaith 

Hospitality 

Network of York 

County, SC, 

Rockhill, SC

● ● ● 3 

Wintergarden 

Women’s 

Shelter, Carrizo 

Springs, TX

● ● ● 3

Union Gospel 

Mission, Dallas, 

TX

● ● 2 

Woman, Inc.,

Galveston, TX

● ● ● 3 

New Haven 

Home, Mineral 

Wells, TX

● ● ● ● 4 

Concho Valley 

Center for 

Human 

Advancement, 

San Angelo, TX

● 1

City of San 

Antonio, San 

Antonio, TX

● ● ● ● 4 

Central 

Piedmont Action 

Council, Inc., 

Farmville,VA 

● ● 2 

The Salvation 

Army, 

Lynchburg, VA

● 1 

County of 

Prince William, 

Woodbridge, VA

● ● ● 3
Appendix IV: Services Provided at 81 Active 

Properties Transferred under Title V, by State

Page 56 GAO-14-739 Federal Real Property

Services

Homeless 

Provider, 

Location (by 

State)

Supportive Services aTransitional HousingReferral ServicesEmergency ShelterPermanent Supportive HousingAdministrative OfficesGoods and Clothing DistributionEducation /Job TrainingDaycare /Day CenterFood DistributionMental HealthWarehouse and StorageNon-Use 

(Potential 

Case Management

Total 

Number 

of 

Services

NE Kingdom 

Community 

Action, Inc., 

Newport, VT

● ● 2 

King County 

Housing 

Authority, Kent, 

WA

● ● ● ● ● 5 

City of 

Redmond, 

Redmond, WA

● ● 2 

Integrated 

Community 

Services of 

Parkersburg, 

Parkersburg, 

WV

● ● ● 3 

Northwood 

Health Systems, 

Inc., Wheeling, 

WV

● ● ● 3 

Wyoming 

Coalition for the 

Homeless,

Cheyenne, WY

● ● 2 

Total Number 

of Services

43 42 37 19 12 11 8 6 5 2 2 2 2 1 192

Source: GAO analysis of HHS information. | GAO-14-739
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 57 GAO-14-739 Federal Real Property

Figure 4: Former Social Security Administration Building

Property Name: Boyle Heights Social Security Building

Location: Los Angeles, California

Property Description: 1 building; .95 acre

Notice of interest date: 2/3/2009

Application date: 3/31/2009

Year transferred: 12/14/2009 (deed conveyance)

Grantee: Volunteers of America, Los Angeles

Homeless Assistance Use: Supportive and referral services

Volunteers of America of Los Angeles (VOALA) is a non-profit human 

services organization committed to serving people in need, strengthening 

families, and building communities. The property consists of a single-story 

masonry building in very good condition. VOALA offers several homeless 

assistance programs at the site including Early Head Start, which 

provides comprehensive services to homeless families with children 

under 4 years of age; Incarcerated Veterans Transition Program, which 

provides employment support for veterans about to be released or just

released from incarceration; Female & Single Head of Household, which 

provides case management services to female and single head-ofhousehold veterans; and Supportive Services for Veteran Families, which 

provides a housing placement program. According to VOALA, the four 

programs served 1,029 individuals in 2013.

Appendix V: Eight Homeless Assistance 

Case-Study Properties

California
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 58 GAO-14-739 Federal Real Property

Figure 5: Former Lowry Air Force Base Building

Property Name: Lowry Air Force Base Building

Location: Denver, Colorado

Property Description: 1 building (6,800 square feet); 1.8 acres

Notice of interest date: 10/06/1999

Application date: 1/06/2000

Year transferred: 6/03/2003 (deed conveyance)

Grantee: Third Way Center

Program Use: Includes shelter, job training, and education

Third Way Center is a non-profit organization that provides transitional 

housing and round-the-clock psychiatric care for at-risk youth in Denver, 

CO. The property was originally part of the Lowry Air Force Base, which 

closed as a result of the Base Realignment and Closure Act (BRAC) in 

1991. Since the property became available as a result of a preRedevelopment Act BRAC action, it was subject to Title V Homeless 

Assistance Program reporting requirements. According to HHS, one 

factor in the long period between the base closure and when the property 

became available was the environmental clean-up that was required at 

the site. When Third Way acquired the property in 2003, the property 

consisted of a one-story building that the provider subsequently 

demolished to construct four residential homes. The organization uses 

this property to provide a number of services to homeless adolescents—

including shelter, meals, job training, mental health treatment, and an onsite, state-approved high school.

Colorado
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 59 GAO-14-739 Federal Real Property

Figure 6: Former Homestead Air Force Base

Property Name: Homestead Air Force Base

Location: Homestead, Florida

Property Description: 0 buildings; 84.2 acres

Notice of interest date: 12/22/1993

Application date: 11/16/1995

Year transferred: 6/28/1996 (deed conveyance)

Grantee: The Miami-Dade County Homeless Trust

Program Use: Includes shelter, education, and mental health treatment

The Miami-Dade County Homeless Trust is an organization within the 

Miami-Dade County government that is responsible for coordinating local 

homeless systems of care. The organization applied for and was 

conveyed 84 acres of unimproved land from the former Homestead Air 

Force Base, which was closed as a result of the Base Realignment and 

Closure Act in 1993. Since then, Miami-Dade Homeless Trust has 

developed the property, including a 300-bed emergency housing facility, a 

192-bed transitional housing facility, and a 580-bed facility for families 

with individuals having disabling conditions. Services at these facilities 

include case management, adult and vocational education, job training, 

and various medical services. There is also a working farm and farmer’s 

market on the property. According to Miami-Dade Homeless Trust, 

homeless assistance was provided at the property to more than 2,000 

individuals in 2013.

Florida
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 60 GAO-14-739 Federal Real Property

Figure 7: Former U.S. Coast Guard Family-Housing Site

Property Name: Stillpond Housing Units, U.S. Coast Guard (4 homes)

Location: Chestertown, MD

Property Description: 4 homes (each approx 1,100 square feet); 1.32 acres

Notice of interest date: 1/31/2002

Application date: 5/10/2002

Year transferred: 8/13/ 2002 (deed conveyance)

Grantee: Crossroads Community, Inc., Centreville, MD

Homeless Assistance Use: Transitional housing for adults in mental health rehabilitation programs.

Crossroads Community, Inc. is a nonprofit organization that provides a 

full array of psychiatric rehabilitation and case management services to 

adults and children through five counties on Maryland’s Eastern Shore. 

The property consists of two raised foyer and two ranch homes located in 

Chestertown, Maryland, but the houses are not contiguous to each other. 

All four houses are being utilized as residences for a Residential 

Rehabilitation Program licensed by the State of Maryland. The program 

provides for licensed, supervised transitional housing for homeless adults 

who have mental illness. The people served are expected to transition to 

a less supervised setting within 24 months. Crossroads Community, Inc. 

initially met strong local opposition to its application and program as a 

result of an unrelated crime that occurred several years prior to the 

property becoming available. The organization was able to overcome 

opposition through a combination of informational meetings and a 

workshop at a local community college. Crossroads Community, Inc 

would like to convert at least two of the houses to permanent supportive 

housing sometime in the future.

Maryland
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 61 GAO-14-739 Federal Real Property

Figure 8: Former Social Security Administration Building

Property Name: Social Security Administration Building

Location: Springfield, Missouri

Property Description: 1 building (17,346 square feet); 1.08 acres

Notice of interest date: 11/1/2005 

Application date: 1/30/2006

Year transferred: 9/5/2007 (deed conveyance)

Grantee: Veterans Coming Home/New Life Evangelistic Center

Homeless Assistance Use: Daytime respite center for homeless adults; case management

Veterans Coming Home Center is a program of New Life Evangelistic 

Center (NLEC), non-denominational, faith-based organization 

headquartered in St. Louis, MO. Although NLEC initially wanted to use 

this property as emergency shelter for homeless veterans, it was unable 

to win the approval of local authorities for this purpose. As an alternative, 

NLEC developed the property as a daytime respite center, providing 

access to food and hot beverages, laundry services, free clothing, and 

referral services, among other services. According to an NLEC 

representative, Veterans Coming Home expanded its outreach to all

members of the homeless population in 2008, its second year of 

operation at the recommendation of HHS. In addition, beginning in 2012, 

Veterans Coming Home introduced counseling and case management 

services through partnerships with other organizations. According to the 

annual report submitted to HHS, Veterans Coming Home provided 

services to 421 homeless persons in 2013.

Missouri
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 62 GAO-14-739 Federal Real Property

Figure 9: Former Sonstelie Hall Army Reserve Center

Property Name: Sonstelie Hall Army Reserve Center

Location: Kalispell, Montana

Property Description: 2 buildings (13,100 square feet and 750 square feet); 2.42 acres

Notice of interest date: 11/5/2007

Application date: 12/06/2007

Year transferred: 7/18/2008 (deed conveyance)

Grantee: Samaritan House

Program Use: Administrative offices, case management, job training.

Samaritan House is a non-profit organization that has provided 

assistance to the homeless population in Kalispell, MT since 1991 

through its several facilities. The organization uses this particular 

property, which consists of a main building and garage, to provide case 

management, job training, tutoring, meetings, and food, clothing and 

furniture distribution. According to Samaritan House, the acquisition of 

this property enabled an increase in capacity at its transitional housing 

facility by moving some of the operations that had been housed there to 

this facility, resulting in the addition of 13 beds. According to Samaritan 

House, the facility was used to provide homeless assistance to more than 

1,100 individuals in 2013.

Montana
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 63 GAO-14-739 Federal Real Property

Figure 10: Former Naval Reserve Center

Property Name: Naval Reserve Center

Location: Kearny, New Jersey

Property Description: 1 building (about 50,000 square feet); 2.63 acres

Notice of interest date: 4/26/2001

Application date: 6/27/2001

Year transferred: 3/27/2002 (deed conveyance)

Grantee: Urban Renewal Corp.

Program Use: Workforce development, GED training, and warming station during winter 

months

The Urban Renewal Corp. is a community-based, non-profit organization 

providing a variety services to vulnerable populations in New Jersey. This 

property consists of a four-story building that was formerly used as a 

Naval Reserve Center. The building is currently used to provide the 

homeless with job training and education, in addition to a variety of social 

services, such as substance abuse and HIV/AIDS counseling, and case 

management. Initially, the Urban Renewal Corp. had intended to use the 

property as a homeless shelter, but after facing strong local opposition, it 

revised its intended program of use to include only non-shelter services to 

the homeless. Although it is not formally used as a shelter, the provider is 

authorized to use the facility as a warming station during the winter 

months to house up to 20 homeless people per night when outside 

temperatures fall below a certain point.

New Jersey
Appendix V: Eight Homeless Assistance CaseStudy Properties

Page 64 GAO-14-739 Federal Real Property

Figure 11: Former U.S. Coast Guard Housing

Property Name: U.S. Coast Guard Family Housing Site

Location: Redmond, Washington

Size: 18 Buildings; 5.1 acres

Notice of interest date: 7/5/1996

Application date: 11/15/1996

Transfer Date: 9/25/1997 (deed conveyance)

Grantee: City of Redmond, Washington

Homeless Assistance Use: Emergency shelter; transitional housing; case management

When the City of Redmond learned that federal real property would 

become available for homeless assistance within its boundaries, it 

retained an “inter-local” governmental organization that it is a member of, 

A Regional Coalition for Housing (ARCH), to assist the city in preparing 

an application and developing a program for the property. The property 

consisted of a 5.1 acre parcel including 18 residences that had been used 

to house U.S. Coast Guard staff. The city contracted with a consortium of 

four homeless assistance providers to rehabilitate and operate the 

existing units for transitional housing on 4.1 acres of the site, reserving 

the remaining acre for a recreational area. In 2003, the consortium 

demolished the original units and replaced them with new buildings that 

included a total of 59 housing units to provide transitional housing for the 

homeless. According to the City of Redmond’s most recent Annual

Utilization Report to HHS, the property, now called Avondale Park, 

provided emergency shelter and transitional housing in calendar year 

2013 to 319 individuals.

Washington
Appendix VI: Comments from the General 

Services Administration

Page 65 GAO-14-739 Federal Real Property

Appendix VI: Comments from the General 

Services Administration
Appendix VI: Comments from the General 

Services Administration

Page 66 GAO-14-739 Federal Real Property
Appendix VII: Comments from the Department 

of Health and Human Services

Page 67 GAO-14-739 Federal Real Property

Appendix VII: Comments from the 

Department of Health and Human Services
Appendix VII: Comments from the Department 

of Health and Human Services

Page 68 GAO-14-739 Federal Real Property
Appendix VIII: Comments from the U.S. 

Interagency Council on Homelessness

Page 69 GAO-14-739 Federal Real Property

Appendix VIII: Comments from the U.S. 

Interagency Council on Homelessness
Appendix IX: GAO Contact and Staff 

Acknowledgments

Page 70 GAO-14-739 Federal Real Property

David J. Wise, (202) 512-2834, or wised@gao.gov

In addition to the contact named above, Amelia Shachoy, Teresa Spisak 

(Assistant Directors), Lindsay Bach, Jennifer Clayborne, Kathleen 

Gilhooly, Geoffrey Hamilton, Delwen Jones, Rosa Leung, John Mingus, 

Josh Ormond, Amy Rosewarne, and Elizabeth Wood made key 

contributions to this report.

Appendix IX: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(542203)
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